Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and, if applicable, the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws if and when they apply.

We have prepared this Privacy Policy to help you understand our practices with respect to the collection, use, and disclosure of information we collect from you through (i) www.wallacefinance.io, its subdomains, and any other website where our Terms of Service are posted; (ii) our online hosted services; (iii) our mobile application and social media pages; and (iv) our marketing activities, events and other activities described in this Privacy Policy (collectively, the “Services”).

1. Key Terms

‍It would be helpful to start by explaining some key terms used in this policy:

We, us, our, Wallace Finance Co., or the Company	Wallace Finance Co. and its affiliates
Personal information	Any information relating to an identified or identifiable individual
Services	Wallace Finance Co.'s website, mobile applications, and related services, information, and communications

2. Personal Information We Collect About You

‍We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)	Name, postal address, billing address, IP address, email address, account name, professional title and company name, profile data (including but not limited to username, email and password used, and other account information).
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Name, address (including city, state, country of residence, postal code), national identification number(s) (e.g., Social Security Number, tax identification number, passport number), state or local identification number(s) (e.g., driver's license or state ID number), telephone number, credit card number, debit card number, other financial information, personal interests, household income range, number of children, age, gender, demographic information, and product and service preferences.
Communications Data	Communications between you and the company by methods including but not limited to: email, social media, the Services (including the Ask Wallace function), or otherwise.
Audio and visual information	Pictures you provide or upload in connection with our Services, and the content and audio or video recordings of phone or video calls between you and us that we record where permitted by law.
User-Generated Data	Any photos, images, comments, questions, messages, investment strategies, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata (including keywords, geographical or location information or similar data).
Commercial, Financial, Marketing, and Promotional information (e.g., records of income, economic standing, investment goals, personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	Records of preferences for receiving our marketing communications and details about your engagements with marketing communications; records of your participation in referral or affiliate programs; stated income, economic standing, and investment goals; any data needed to complete transactions and investments, add or withdraw funds, set up recurring events (this may include collecting payment card information or bank account number).
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)	We use cookies to collect certain information about your searching, browsing and purchase activities to recommend additional products based on your prior activity.
Geolocation data	IP address, location of access and purchase.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	We use cookies to collect certain information about your searching, browsing and purchase activities to recommend additional products based on your prior activity.

This personal information is required to provide products to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing products to you.

3. Third-Party Integrations

Certain aspects of the Services may allow you to link or integrate third-party products and services to enable certain features and functionalities with the Services. If you choose to use these features or functionalities, you may be asked to create an account with a third party that provides such features or functionalities or link your existing third-party service account with the Services (and, by doing so, agree to the privacy policy and/or terms and conditions of that third party). You may also be asked to authorize the Services to collect information from the third party on your behalf. We will then collect information (such as your username or user ID associated with that third-party service) from you and/or that third party as necessary to enable the Services to access your data and content stored with that third-party service. Once the authentication is complete, we have the ability to access information you provided to us or was otherwise collected by the third party service in accordance with the privacy practices of that third party. We will store the information and data we collect and associate it with your account, and we will use that information and data to enable the integration of the Services with the third-party service and to perform actions requested or initiated by you, or that are reasonably necessary to carry out instructions provided by you.

4. Information Collection and Tracking Technologies

‍When you download, access, or use the Services, it may use technology to automatically collect or utilize:

Ask Wallace Technologies. Our “Ask Wallace” technologies which facilitate the “Ask Wallace” features that you can use to structure your investing. We use artificial intelligence providers to power our Ask Wallace technologies, such as OpenAI and Perplexity. OpenAI and other third parties may access and use personal information that you share through online chats for the purposes described in this Privacy Policy.
Cookies (or mobile cookies). A cookie is a small file placed on your computer or smartphone. Cookies are small text strings that the websites visited by a user install on the user’s terminal. These strings are then re-transmitted to the site that installed them upon further requests by the user. When the user also receives cookies sent by other sites or web servers during site navigation, those cookies are considered third-party cookies. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your computer or smartphone. However, if you select this setting, you may be unable to access certain parts of our Services.
Error Tracking. Technologies such as those provided by Sentry, that track user input and interaction through the Service to flag errors in AI systems and other integrated systems. This tracking includes input/output of Services. You can learn more about Sentry at https://docs.sentry.io/security-legal-pii/.
Local Storage Technologies. Storage technologies like HTML5, provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Session-replay Technologies. Technologies such as those provided by PostHog that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about PostHog at https://posthog.com/privacy.
Web Beacons. Pages of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Services statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

5. How Your Information is Collected

We collect most of this personal information directly from you – by phone, text, email, your orders, or via our website. However, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from you when you provide it to us, such as when you make a purchase, visit or use our website, place an order with us, contact us by email, by phone, or by online chat, register for an online account, participate in a contest or sweepstakes, respond to a survey, comment on blog posts, engage in a promotional activity, or sign up for emails, newsletters, or marketing;
Certain information from third parties, such as data providers, social media platforms and networks that you use in connection with our Services, or that share or allow you to share information with us; service providers that we use that provide us with information about you and the devices you use online; and other third parties that we choose to collaborate with in order to make the Services and its services available for your use;
From a third party with your consent (e.g., your bank or credit card company);
Automatically when you use the Services, including automatically collected information, but which generally does not include personal information unless you provide it through our website or you choose to share it with us;
From cookies on our website; and
Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

6. Third Party Information Collection

‍When you use the Services or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

Advertisers, ad networks, and ad servers;
Analytics companies;
Your mobile device manufacturer; and
Your mobile or internet service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred within the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

7. How and Why We Use Your Personal Information

‍Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory obligations;
For the performance of the Services;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Wallace Finance Co.	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best products for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our products to: ⎯ existing and former customers; ⎯ third parties who have previously expressed an interest in our products; ⎯ third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing, prospective and former customers
External audits and quality checks, e.g. licensure verification and related audits	For our legitimate interests or those of a third party, i.e. to maintain licensure so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations
Training and improving Artificial Intelligence (AI) or Machine Learning (ML) models to enhance our products and services, develop new technologies and capabilities, optimize user experience, enhance security measures, or improve personalization and targeted services.	For our legitimate interests or those of a third party, where we determine that processing is necessary and where such legitimate interests do not override the interests or fundamental rights and freedoms of the data subject.

8. Use of Personal Data for Artificial Intelligence and Machine Learning (AI/ML)

‍We may, at our discretion, collect, process, and utilize personal data for the purposes of training, developing, and improving AI/ML models. Our commitment to transparency, data protection, and compliance with the General Data Protection Regulation (GDPR) is the basis for this provision.

Scope of Data Collection and Processing:
- We may collect and process various categories of personal data that could be utilized in AI/ML model training, including but not limited to:
  - Personal Identifiers
  - Demographic Information
  - Transactional data
  - Behavioral Data
  - User-generated content
  - Device and technical information
- Personal data may be collected through various touchpoints, as described in this Privacy Policy.

Purposes and Legal Basis for Processing
- The personal data collected may, at our discretion, be used for AI/ML-related purposes, which could include:
  - Training and improving AI/ML models to enhance our products and services
  - Developing new technologies and capabilities
  - Optimizing user experience
  - Enhancing security measures
  - Improving personalization and targeted services
- The processing of personal data for AI/ML purposes is based on:
  - Legitimate interests, pursuant to Article 6(1)(f) of GDPR, where we determine that processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by the interests of fundamental rights and freedoms of the data subject.
  - In specific cases where explicit consent is required and obtained pursuant to Article 6(1)(a) of GDPR.
Data Protection Safeguards. We implement appropriate technical and organizational measures to protect personal data used in AI/ML processes, in line with GDPR requirements and industry standards.
‍Data Subject Rights ‍
- Data subjects retain their rights under GDPR, including the right to access, rectification, erasure, and objection to processing.
- While we strive to accommodate data subject rights, the nature of AI/ML processing may impact our ability to fully execute certain requests, particularly where data has been aggregated or transformed for model training.

International Data Transfers. We may transfer personal data outside the European Economic Area (EEA) for AI/ML purposes, ensuring appropriate safeguards are in place as required by GDPR.
Transparency and Information. We will provide general information about our AI/ML data processing activities through this Privacy Policy and other appropriate channels, reserving the right to withhold specific details that may compromise our proprietary technologies or competitive position.
Data Retention and Deletion. Personal data used for AI/ML purposes will be retained as long as necessary for the purposes described herein, subject to our data retention policies and legal obligations.
Automated Decision-Making and Profiling. We may engage in automated decision-making and profiling as part of our AI/ML activities. Where such processing produces legal effects or similarly significantly affects data subjects, we will provide appropriate safeguards and information as required by GDPR.
Children’s Data. We do not knowingly use personal data of children under the age of 18 for AI/ML purposes without appropriate parental consent.
Updates and Revisions. We reserve the right to update this AI/ML provision at any time. Material changes will be communicated through appropriate channels.

9. Promotional Communications

‍We may use your personal information to send you updates (by email, text message, telephone or mail) about our products, including exclusive offers, promotions or new products.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect.

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message. You may also text STOP to cancel.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

We may offer features that help users invite their friends or contacts to use the Services, and we may collect contact details about these invitees so we can deliver their invitations. You are prohibited from referring someone to us or sharing their contact details with us unless you have their permission to do so.

10. Who We Share Your Personal Information With

‍We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. We do not sell, trade or otherwise transfer personal information to outside parties (except to the third parties with whom we have contracted to provide services to us, as detailed in the applicable section below). In addition, we may disclose personal information that we collect or you provide:

To our affiliates, including companies within the Wallace Finance Co. group of brands and companies.
To service providers we use to help deliver our Services to you, such as payment service providers, advertising partners.
To other third parties we use to help us run our business, such as marketing agencies or website hosts, which utilize their own terms and conditions and privacy policies:
- Plaid Privacy Policy
- Alpaca Securities LLC Disclosures
- Amazon Web Services Privacy Notice
- Supabase Privacy Policy
To third parties approved by you, including social media sites you choose to link your account to or third party payment providers.
To our insurers and brokers.
To our banks.
To parties in business transactions, such as a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party.

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Wallace uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Services, you grant Wallace the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid. Wallace also uses financial institutions to process your ACH funds transfers from your funding source bank account to the Brokerage for use of the Services.

11. Personal Information We Disclosed for a Business Purpose

‍In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

12. Where Your Personal Information is Held

‍Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

13. How Long Your Personal Information Will Be Kept

‍We will keep your personal information while you have an account with us or while we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To satisfy any legal, accounting, or reporting requirements;
To establish or defend legal claims;
To enact any fraud prevention policies;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

14. Accessing and Correcting Your Personal Information

‍You can review and change your personal information by logging into the Services and visiting your account profile page.

You may also contact customer support to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

15. Links to Other Sites

‍Please be aware that our website will typically contain links to other sites that are not governed by this Privacy Policy but other privacy policies that will often differ. We encourage users to review the privacy policy of each Website visited before disclosing any personal information.

16. Children

‍Our services are not intended for use by children under the age of 18 (or other age as required by local law) and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take reasonable steps to delete such information from our files as soon as it is practicable. If you have reason to believe that a child under the age of 13 in the US, or under 16 in the EU,

has provided Personal Information to Wallace Finance Co., please contact us at support@wallacefinance.io so we can endeavor to delete that information from our databases and other data infrastructure.

17. Your Rights Under the CCPA

‍You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Make a good-faith effort to delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods to you, if that difference is reasonably related to the value provided to our business by your personal information.

18. Keeping Your Personal Information Secure

‍We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

WALLACE FINANCE CO. MAKES NO REPRESENTATIONS OR WARRANTIES WITH REGARD TO THE SUFFICIENCY OF THESE SECURITY MEASURES. WE SHALL NOT BE RESPONSIBLE FOR ANY ACTUAL OR CONSEQUENTIAL DAMAGES (OR ANY OTHER DAMAGES OR LIABILITY OF ANY KIND WHATSOEVER, WHETHER AS A RESULT OF NEGLIGENCE OR OTHERWISE) THAT RESULT FROM A LAPSE IN COMPLIANCE WITH THIS PRIVACY POLICY BECAUSE OF A SECURITY BREACH OR TECHNICAL MALFUNCTION.

19. How to Exercise Your Rights.

‍If you would like to exercise any of your rights as described in this Privacy Policy, please email us at support@wallacefinance.io.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driver’s license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

20. Disclosures to Residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia

‍The disclosures in this section apply solely to individual residents of the States of Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia. Privacy laws in Colorado, Connecticut, Utah and Virginia give residents certain rights with respect to their personal data, and privacy laws in Montana, Oregon, and Texas will give residents certain rights with respect to their personal data when they take effect. Those rights include:

Right to Access Information: You have the right to access and obtain a copy of your personal data.
Right to Request Deletion: You have the right to request that we delete personal data provided by or obtained about you.
Right to Correct: You have the right to correct inaccuracies in your personal data.
Right to Opt-Out of Targeting Advertising. You may ask us not to use or disclose your information for the purposes of targeting advertising to you based on your personal data obtained from your activity across different businesses, services, websites, etc.
Right to Opt-Out of Personal Information Sales to third parties.

To Submit a request to exercise your access, deletion, or correction privacy rights, please email us at support@wallacefinance.io with the subject line “Privacy Rights Request” and let us know in which state you live.

Residents of Colorado, Connecticut, Montana, Oregon, Texas, and Virginia may appeal a refusal to take action on a request by contacting us by email at support@wallacefinance.io.
Residents of Oregon may request that we provide a list of third parties to which we have disclosed personal data. To make such a request, please follow the instructions above for submitting an access, deletion, or correction request.

21. Nevada-Specific Disclosures

For residents of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about a resident. Although we do not currently sell covered information, please contact us at support@wallacefinance.io to submit such a request.

22. Changes to This Privacy Notice

‍This privacy notice was published on March 1, 2026 and last updated on the date set forth above. We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email. By accessing or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer to this Privacy Policy on a regular basis.

23. How to Contact Us

‍Please contact us by email if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:

Our Contact Details:
‍
Email:
support@wallacefinance.io

Mail:
8 The Grn, Ste B
Dover, DE 19901