Vestwell

Updated: October 2025

Vestwell Holdings Inc. and our subsidiaries (referred to as "Vestwell") are committed to protecting the privacy of individuals who visit, access, or use our websites, the Vestwell platform, or the Gradifi Powered by Vestwell platform (collectively, our “Sites”). This Privacy Policy explains what information we collect, why we collect it, how we use that information, and the choices we offer relating to the information we collect from or about you. Some of the information we may collect from you constitutes non-public “Personal Information.” Our collection, sharing, and use of Personal Information is governed by the privacy notice that we deliver to you pursuant to applicable state or federal law.

When you visit our Sites, enter into an agreement with us for our services, register for a Vestwell account, attend one of our events, engage with any of our social media content, or subscribe to our blog, you agree to the terms of this Privacy Policy as well as any other agreements you accept when registering for a Vestwell account. We will review and update this Privacy Policy so please review it periodically to be sure you are still comfortable with its terms. We reserve the right to use and disclose aggregated or deidentified information for any commercially reasonable purpose.

1. What Information We Collect About You

We collect information about you in various ways. Some of this information may be considered “Personal Information” under applicable law. Personal Information is information that identifies, relates to, describes, or can be reasonably linked, directly or indirectly, to you as a particular individual or household. Personal Information does not include information that is lawfully made available through federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public.

We collect this information from you directly, from your current or prior employer or a third party acting on their behalf. We may also obtain Personal Information from third parties that we have partnered with or have engaged as service providers. For example, we may create information based on our analysis of the foregoing with other information we have collected from you.

Plan Sponsors, Participants, Beneficiaries, and Alternate Payees who use Vestwell’s services:

In order to perform our responsibilities, Vestwell receives information from you or someone acting on your behalf, such as your employer, a Third Party Administrator, or your employer’s payroll provider. This includes:

• Full legal name
• Contact information
• Demographic information
• Social Security Number or other identifiers
• Employment-related records
• Sensitive Personal Information

Individuals who visit our Sites:

We collect information about you automatically using technologies such as cookies, which may include device-specific information, your IP address, and the pages accessed on our Sites.

Individuals who register for or attend one of our events:

We collect information directly when you register or attend events, including your name, contact details, and marketing channel by which you learned about Vestwell.

2. How We Use the Information

We may use the information we collect from you in various ways, including:

• To operate our Sites.
• To deliver information, products, or services that you requested.
• To communicate with you regarding changes to our Sites or services.
• To help improve our Sites and deliver a personalized experience.
• To comply with legal obligations.

3. How We Share Information

We may share collected information:

• With affiliates and partners providing services on our behalf.
• With regulatory bodies and legal authorities when required.
• When you request our services or products.

4. Cookies and Tracking Technologies

Our Sites may use cookies and other tracking technologies for a variety of purposes:

• To provide functional capabilities.
• For analytics.
• To personalize the user experience.

5. How Does Vestwell Protect My Personal Information

We protect your Personal Information by physical, electronic, and procedural safeguards. However, the security of your information also depends on your actions and the security of your own device.

6. How Long Does Vestwell Keep My Personal Information

Vestwell retains Personal Information as necessary to provide services or as required by law.

7. Your Choices

You can manage your cookie preferences through your web browser. For any specific opt-outs, particularly regarding marketing communications, please contact us.

8. Additional Information for Residents of Other States

Residents of various states have rights relating to their Personal Information, including the right to access, correct, or request deletion of their data.

9. How to Contact Vestwell

If you believe we have not adhered to this Privacy Policy, please contact Vestwell by email at help@vestwell.com or by mail at Vestwell Holdings Inc., Legal Department, 360 Madison Avenue, 15th Floor, New York, New York 10017.