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Your Privacy Matters

Can Serve Free LLC's number one priority is to establish fiduciary relationships with our Clients based on trust. Your privacy is essential to earning and keeping that trust. This tenet drives all the decisions we make, as well as how we gather, use, and store any information we acquire from you.

We created this Privacy Policy to be as clear and direct as possible about how we gather and use your non-public personal information and other types of personal information (“Personal Information”) and to assist you in exercising your privacy rights.

Introduction

Can Serve Free LLC currently offers investment advisory and portfolio management services and may offer additional products and services in the future (collectively, the “Services”), through the company's website, www.canservefree.com (“Site”) and our mobile applications (“App”). This Privacy Policy describes how Can Serve Free LLC treats your Personal Information when you use our Site, App and/or Services.

As stated in the Terms & Conditions document, we define a User as an individual who visits our website or mobile application to evaluate our services or to peruse the website for inspirational and educational purposes. A Client, on the other hand, is an individual who signs an Investment Advisory Agreement (“Contract”) and Client Account Agreement that entitles the Client to receive fee-based professional investment advisory services. This Privacy Policy applies to both Users and Clients.

Our Privacy Policy, Terms & Conditions, and Client Account Agreement govern various aspects of your use of our Site, App, and Services.

Information Collection

Examples of instances when we collect Personal Information include:

  • When you answer risk-tolerance questions on the Site or in the App to determine what type of portfolio (conservative or less conservative) might be appropriate for you as a Client.
  • When you register to open an account as a Client.
  • When you contact our Client Service Portal with questions.
  • When you agree to enter into an Investment Advisory Agreement (“Contract”) and Client Account Agreement.

Whenever Can Serve Free LLC collects Personal Information, we endeavor to make available this Privacy Policy and our Terms & Conditions.

Information We Collect from Clients

We collect Personal Information from Clients, including but not limited to:

  • Full legal name, physical address, e-mail address, telephone number, Internet Protocol address, birth date;
  • Investable assets, income information, and other financial planning information about your household; and
  • (With permission from the Client) account numbers, and login credentials for the financial accounts you choose to link to our Services, any challenge and/or security questions associated with those linked accounts, and any information contained in those linked accounts.

    • Note: The section labeled “Information We Collect When Acting As Your Authorized Agent” provides additional details regarding how we use and protect this information.

Additional Information We Collect from Clients

In addition to the information described above, Clients provide us with additional Personal Information, including but not limited to:

  • Birth date, Social Security Number, country citizenship, and marital status;
  • Full legal name, birth date, and Social Security Number of any joint owners that Clients choose to list;
  • Government-issued identification documents (i.e., state driver’s license or country passport) and self-portrait photographs (“selfie”) for purposes of identity verification; and
  • Investment objectives, approximate net worth, and other information required by federal and industry laws and regulations, such as employment information and stock restrictions (see our Client Account Agreement).

You are not required to provide these items to us to access the public view of the website as a general User. However, Users who choose not to provide these items to us will not be able to become Clients.

Information We Collect When Acting As Your Authorized Agent

Can Serve Free LLC's Clients have the option to input information from accounts at outside third-party financial institutions onto their Can Serve Free LLC Client Profile and Investment Dashboard on our Site or in our App. Although there is no requirement to do so, if you choose to enable Can Serve Free LLC to collect information from your outside accounts, Can Serve Free LLC can retrieve information maintained by your outside financial institutions (“Outside Account Information”) as described in this section.

By linking your outside accounts to your Can Serve Free LLC account, you provide Can Serve Free LLC access to your Outside Account Information, which may include prior and current brokerage account balances, your transaction history, and stock holdings from your linked outside financial institutions. The major components of this Outside Account Information will be displayed on your Can Serve Free LLC Client Profile and Investment Dashboard.

By choosing to use our Services to aggregate and analyze your outside Account Information, you expressly authorize and direct Can Serve Free LLC, on your behalf, to access all Outside Account Information available via the login credentials you provide. As Can Serve Free LLC’s service provider, our third-party provider is responsible for storing your credentials, collecting, and processing your Outside Account Information, and providing it to us using the login credentials you supply. Any Outside Account Information that Can Serve Free LLC receives from our third-party provider is in read-only format and Can Serve Free LLC cannot alter the Outside Account Information maintained by your third-party institution. All transmissions of your Outside Account Information and your login credentials between our third-party provider and Can Serve Free LLC are encrypted in transit. Can Serve Free LLC retains your Outside Account Information collected via this account-linking service in accordance with our regulatory recordkeeping requirements, as permitted by law, as described elsewhere in this Privacy Policy, and as required in connection with the maintenance of your account and the Services we provide to you.

Clients may request deletion of their Outside Account Information in accordance with the “Retention and Deletion” section below. Can Serve Free LLC does not share your Outside Account Information with external parties except in limited cases relating to fraud investigations. In such fraud investigations, we may share (as required by law) certain aspects of your Outside Account Information with your linked third-party institution. If you choose to remove or deactivate a link to an account with a third-party institution, we will not retrieve any new Outside Account Information for that account unless you re-link that account in the future. The control of access to Account Information always remains with the Client.

Information We Do Not Collect

Can Serve Free LLC does not track or collect any sensitive information about you. This is known as 'special category data' and includes information about a person's race, health, religion, ethnicity, and political opinions or affiliation.

Information Regarding Children

Due to the nature of our business, our Services are not available to minors under the age of eighteen years old. Can Serve Free LLC does not knowingly solicit Personal Information directly from or about persons under the age of eighteen.

If you are under the age of eighteen, please do not submit any Personal Information to Can Serve Free LLC.

If you are a parent or guardian who becomes aware that, without your consent, your child under the age of eighteen has directly provided us with Personal Information, you should contact us immediately at support@canservefree.com, and we will delete such information from our files to the extent permitted by regulatory requirements.

How We Use Information

No Renting, Selling or Trading Out List

We will never rent, sell, or trade your Personal Information to anyone.

User Personal Information

We utilize the Personal Information of our Clients for a variety of business purposes, such as to help our Clients evaluate our Services, offer new products and services, enhance our Services, and for research and internal analysis.

Client Personal Information

Can Serve Free LLC stores, processes, and maintains Personal Information of our Clients for a variety of business reasons such as to provide client support, analyze and improve our Services, offer new products and services, and provide our Services to Clients in accordance with the rules of regulatory authorities.

Identity Verification for Clients

We may use third-party vendors for identity verification. These vendors analyze whether the Client's “selfie” matches the government-issued identity document.

Social Media and Links to Other Websites and Applications

This Privacy Policy and these terms apply only to Can Serve Free LLC-operated Services and applications. Please note that our Site and Apps may for your convenience contain links to other websites, applications, social media accounts, and information that are not operated by Can Serve Free LLC. Can Serve Free LLC does not control these linked third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Any Personal Information you choose to provide to linked third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of each company or website before submitting any Personal Information. Some third parties may choose to share their Users' Personal Information with us; that sharing is governed by that company's privacy policy, not Can Serve Free LLC's Privacy Policy.

Mobile Computing

Can Serve Free LLC provides a website and online resources that are specifically designed to be compatible for use with mobile computing devices. Mobile versions of our Site are governed by the provisions hereunder related to the Site and may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts.

Information Sharing and Onward Transfer

We will not share or disclose your Personal Information (whether you are a current or former User or Client) to any unaffiliated third parties except:

  1. To Protect Others or Ourselves. We may share your Personal Information as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front-running or scalping, situations involving potential threats to the personal safety of any person if we believe doing so is required or appropriate: to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; to protect your, our or others' rights, property, or safety; enforce our policies or contracts; or collect amounts owed to us.
  2. Service Providers. There are certain circumstances in which we may share your Personal Information with unaffiliated third-party service providers, including to perform certain business and technology-related functions and to support the provision of the Services. We may share your Personal Information with unaffiliated third-party service providers for the provision of certain services, including but not limited to the following: mailing information; data processing and storage; payment processing; identification verification and fraud detection; customer support; and marketing. We do not share Personal Information with any third parties for their own marketing purposes.
  3. Business Partners. We may provide Personal Information to business partners with whom we jointly offer products or services.
  4. Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction, as permitted by law and/or contract. Full disclosure to Clients would occur under such scenarios.

How Long We Retain Data

We securely store your information and hold it for as long as reasonably necessary to provide our Services to you in accordance with applicable law. We review our retention periods for Personal Information to comply with the data minimization and limitation principles in data protection law, to ensure we only collect and retain the data we need to serve you.

Your Choices and Opting Out

General

You have choices regarding the use and disclosure of your Personal Information, as set out in this Privacy Policy.

You may decline to provide Personal Information to Can Serve Free LLC. Declining to provide Personal Information may disqualify you from using Can Serve Free LLC Services, the Site, the App, and other Features that require certain Personal Information.

Opting-Out-Obtaining and Withdrawing Consent

Where you have consented to Can Serve Free LLC's use of your Personal Information, you may withdraw that consent at any time by contacting us by email at support@canservefree.com.

Clients cannot opt out of providing Can Serve Free LLC Personal Information and continue to use the Services.

Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal and regulatory purposes as described above. In addition to withdrawing consent by contacting us, Clients and Users must close their account(s) to opt out of further providing Can Serve Free LLC with Personal Information.

Email and Telephone Communications

Can Serve Free LLC may use your Personal Information to communicate with you regarding our Services or to tell you about Services that could be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at support@canservefree.com.

Please note that you cannot opt out of administrative communications such as regulatory, billing, or service notifications, or updates to our Terms & Conditions or this Privacy Policy.

Mobile Devices

We may send you push notifications through our mobile application. You may at any time opt out of receiving these types of communications by changing the settings on your mobile device.

Accessing Your Personal Information

Clients may contact us at support@canservefree.com with any questions on how to access their Personal Information.

  • Can Serve Free LLC provides all Clients with continuous access to their Personal Information via the Site which contains information about account status, securities positions, and balances.
  • Clients can access or amend their Personal Information at any time by signing in to their Can Serve Free LLC account via our Site or App.
  • Your requests will be processed consistent with existing laws, including without undue delay and in accordance with any required time frames. Although Can Serve Free LLC makes good faith efforts to provide individuals with immediate access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information is protected from disclosure by certain privileges and protections, where doing so would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any instance, we will endeavor to provide you with an explanation of why that determination has been made within one month of the request, a contact point for any further inquiries, and any other legally required information.
  • To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access or making any changes to your Personal Information.
Retention and Deletion

Can Serve Free LLC retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Site, App, or Services, or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

Due to regulatory recordkeeping obligations, we may retain information related to you and your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies, or in accordance with applicable laws.

User Deletion Requests. If you are a Client (as defined in the Introduction of this Privacy Policy) you may request deletion of Personal Information by contacting support@canservefree.com and providing sufficient information to identify your account and prove that you are the owner of the identified account or an authorized representative. Please note, if you utilize a third-party data deletion request company to make these requests, you must personally provide us with separate written authorization before we process your request.

Client Deletion Requests. In connection with separate regulatory recordkeeping obligations imposed on Can Serve Free LLC, we must maintain and cannot delete Personal Information associated with our Clients.

Other Important Information

Security

Can Serve Free LLC takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free; therefore, we cannot fully ensure or warrant the security of any information you transmit to us.

International Transfers

In certain cases, Can Serve Free LLC may transfer Personal Information internationally. We handle any Personal Information transferred internationally in accordance with this Privacy Policy and take measures to protect that information.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time as we deem it necessary at our sole discretion. If there are material changes to this Privacy Policy, we will notify you as required by applicable law.

Can Serve Free LLC encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with Can Serve Free LLC after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided to you by us. Each version of this Privacy Policy will be identified on this page by its effective date.

This document constitutes Can Serve Free LLC's complete Privacy Policy for Can Serve Free LLC and its affiliates and the Services, Site and App.

Questions and Contacting Us

If after reviewing this Privacy Policy, you would like to submit a request to exercise your rights as detailed in this Privacy Policy or have any questions or privacy concerns, please contact us by email at support@canservefree.com.

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