Aspiration Privacy PolicyEffective Date: 12/26/2018

Aspiration is a company built on trust. We gather client information because it’s the law or because it helps us provide you with our products and services. We will never sell or share your personal information to any third-party unless we are legally required to do so, we have your permission, or because it helps us serve you. Read the details below:

This Privacy Policy describes how Aspiration (Aspiration Partners, Inc.; Aspiration Fund Adviser, LLC; Aspiration Financial LLC; and the investment funds we manage) collect, use, and share your personal information. Please read this Privacy Policy carefully to understand what we do.

Aspiration gathers information from our clients in the course of our operations. This Privacy Policy delineates how Aspiration handles personal information when users access our website or mobile app (“Site”). Further policies may govern information concerning specific products accessed by our clients or information collected from sources other than this Site. For example, nonpublic personal information that we collect about our clients in connection with providing a financial product or service is subject to our Privacy Notice.

All users who access our Site become users pursuant to Aspiration’s Privacy Policy and Terms of Use and thereby signify their consent to said policies and terms.

Information We Collect

Aspiration collects and maintains personal information provided by and related to our clients so that we may provide our products and services. The types of personal information we collect and share depends on the product or service you have with us. This information can include but is not limited to: name, Social Security number, date of birth, contact information, employment information, assets, investment information, retirement assets, transaction history, checking account information, security purchase history, account balances, account transactions, and wire transfer transactions. We also collect any information that you voluntarily provide to us when you use the Chat function, fill out the Contact form, or submit comments using our Feedback form. If you are a member of a social media network, we will also collect any information that you provide to us via your communications with us through our presence on these social media networks. Please be aware that any such activity is subject to these social media networks’ own privacy policies.

We may also collect personal information about you from third party sources, such as consumer reporting agencies, which we may combine with personal information that you provide to us.

Our Site may also collect non-personally identifiable information about your use of the Site, such as browser and device information, browser type, browser language, hardware settings, device type, operating system, system activity, the date and time of your visit, the URL you were on before you came to the our Site, data collected through automated electronic interactions, application usage data, the number of your visits, the length of time spent using or accessing our Site, demographic information, geographic or general geo-location information, and statistical and aggregated information. If we combine any of this non-personally identifiable information with personal information, we will treat the combined information as personal information.

Use of Personal Information

We use your personal information to provide you with our products and services, to communicate with you about other products and services that may be of interest to you, to improve our product and service offerings, to protect the Site and our business operations, to comply with the law or legal proceedings, to conduct legitimate business purposes, to fulfill your requests, and for any other purpose to which you consent, or as described in this Privacy Policy or our Privacy Notice.

Use of Non-Personally Identifiable Information

We may use non-personally identifiable information regarding Aspiration’s current and potential clients, including but not limited to demographic, geographic, or aggregated client information for any legitimate business purposes.

We Limit Sharing of Personal Information

We will only share personal information with third parties as described in this Privacy Policy, for any purpose to which you consent, or as required by law. We will share your personal information with certain third-party service providers as permitted by law in order to deliver our products and services to you. Aspiration and certain third-party service providers may use and share personal information for reasons that include but are not limited to: account opening and validation; to comply with federal, state, and local law; to process transactions; to send information to clients and client-related parties, such as companies in which you choose to invest; to improve Aspiration services; and to protect the security and integrity of our businesses, properties, affiliates, and clients. Third party-service providers may include, but are not limited to, fund accountants, custodians, transfer agents, client selected charities, and accounting firms.

We only share personal information in extremely limited cases, such as with our business partners, as appropriate, to conduct our operations and to maintain the relationships that allow us to provide you with our products and services.

We may also share your personal information with relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, stock, or assets (including in connection with any bankruptcy or similar proceedings).

We will also share personal information with third parties in order to respond to legitimate and legal requests from governmental authorities or in connection with other legal proceedings. We will also share personal information with third parties in other ways necessary to comply with applicable law, as well as to investigate, prevent, or take action regarding illegal activities, suspected fraud, violation of our rights or the rights of others, situations involving potential threats to the physical safety of any person (or any other similar situation), or violations of the Privacy Policy or Terms of Use.

Security Safeguards

Aspiration stores and maintains data with physical, administrative, and electronic safeguards that comply with federal and state laws and regulations. We limit access to user and client data to the extent possible to those employees with authorized access, and we take other measures to protect client information, which include computer safeguards and secured files and buildings. Our service providers are held accountable for adhering to strict policies and procedures to prevent any misuse of your personal information.

We use our reasonable best efforts to protect personal information, however no method of transmission or method of data storage is 100% secure. Despite our reasonable best efforts, we cannot assure that personal information that we collect will never be disclosed in a manner inconsistent with this Privacy Policy. If you see any unrecognized activity in your account, please contact Aspiration Security immediately at security@aspiration.com or 800-683-8529.

Your use of the Aspiration Site acknowledges that Aspiration is not liable or responsible for any unauthorized access to personal information, and you hereby release Aspiration from any and all claims arising out of or related to an unauthorized or inadvertent breach of data or violation of our Privacy Policy or Terms of Use.

Information Posted to the Aspiration Platform

Aspiration is not responsible for any user information shared in public forums such as blogs, chats, videos, or social media (“Platform”). Aspiration retains full, irrevocable, royalty-free, worldwide sublicensable, and perpetual intellectual property rights to any user-generated content uploaded, shared, transmitted, or otherwise publicly disseminated on the Aspiration Platform. Aspiration can store, use, reproduce, modify, and adapt such content and will retain full rights to any derivative works or compilations of such content. Users warrant by their actions that they have the necessary rights to grant such licenses to Aspiration. Aspiration can further delete such content at any time and for any reason.

Aspiration has no obligation to monitor or ability to control the information users publicly place on our Platform. We do not endorse any opinion, recommendation, and information that is expressed in this fashion. By accessing the Platform, users waive any rights or remedies against Aspiration in relation to such data.

Cookies and Similar Technologies

We use cookies on the Site to monitor how the Site is used, to customize content, to identify problems with the Site, to improve the Site, to analyze Site traffic and for other analytics purposes, to monitor the security of the Site, and to gauge the effectiveness of our communications. Most web browsers allow you to adjust your preferences to reject cookies or to receive notifications before they are placed. If your browser is set to reject cookies, you may continue to use the Site, but some aspects of the Site may not function as intended.

Analytics

Our third party vendors assist us in conducting site analytics for our website and mobile app. For example, we use Google Analytics to perform such services for our website for the purposes discussed above. You may learn more by clicking here, and you can opt out of the use of cookies in web browsers by Google Analytics by clicking here.

Advertising

While you are on Aspiration’s Site, using our mobile app, or on other websites, online ad networks we work with may use cookies, pixel tags, and similar technologies, in order to understand your interests based on your (anonymous) online and in-app activities, and thus to tailor more relevant ads to you. We may also allow third-party cookies that track users over time and across third-party websites in order to serve targeted advertisements. If you do not wish to receive such targeted advertising, please visit the Network Advertising Initiative Consumer Opt-Out Page at www.networkadvertising.org/choices, the Digital Advertising Alliance Consumer Choice page at www.aboutads.info/consumers, or visit the websites of our advertising vendors to opt-out. To opt out in mobile apps, please download the Digital Advertising Alliance's AppChoices tool at www.aboutads.info/appchoices. (This will not prevent you from seeing ads; the ads simply will not be delivered through these targeting methods.)

The Site does not respond to browser “do not track” signals.

Contact Information and Opt Outs

Clients can unsubscribe from marketing emails from Aspiration and affiliated third parties utilizing your personal information, including your creditworthiness, on a forward-going basis by contacting Aspiration or clicking on the unsubscribe link contained in each of our marketing emails.

Please note, however, that Aspiration clients cannot opt out of receiving administrative messages.

Aspiration is not responsible for the privacy, security, or information policies of third party links from or on the Aspiration Site. Aspiration may, from time to time, recommend third-party service and product providers to its clients. In such cases, we will only share personally identifiable client information with such third parties if our clients indicate an express interest in learning more. Any third party offering that our users or clients accede to will be governed by that third party’s privacy and commercial policies.

Children

Aspiration’s Site is not directed toward anyone under the age of 18. We will endeavor to delete personally identifiable information provided by minor children without their parent’s or guardian’s consent upon notification by said parent or guardian in a time and manner that is commercially reasonable. Any such notification should be sent to privacy@aspiration.com.

Privacy policies may change from time to time. If we update our Privacy Policy, notification of such changes will occur on this page and/or in an email notification.

Please direct any questions to privacy@aspiration.com or 800-683-8529.