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Privacy Policy

January 2025

This Privacy Policy describes the current policies and practices of Couplr, Inc (“Couplr”) with regard to Personal Data (defined below) collected by Couplr using its website: www.couplr.ai (“Website”) and its related web application.

This Privacy Policy is periodically updated. Please check back on a regular basis for any changes. If there are changes to this Privacy Policy, Couplr will post an update on its website alerting users to the changes.

A USER’S CONTINUED USE OF THE WEBSITE AFTER UPDATES TO THIS PRIVACY POLICY SHALL SERVE AS EXPLICIT CONSENT TO THE UPDATED TERMS.

PERSONAL DATA COLLECTED

The term “Personal Data” refers to personally identifiable information about a person, such as a person’s full name, birth date, e-mail address or mailing address, phone number and any other information that can be used to identify or contact a specific person.  The categories of Personal Data collected by Couplr are as follows: Identifiers (first and last name, e-mail address, password), Professional or Employment Related Information (bio and answers to survey questions), Sensitive Personal Information (passwords).

The only Personal Data Couplr currently collects through its Website and web application is the Personal Data that is provided to Couplr to obtain access to the site. Currently, Couplr collects the following information from users, depending on their user type selected during the sign-up process:

Personal Data from Users Seeking a Financial Professional

  • First & Last Name
  • E-Mail Address
  • Password
  • Answers to Survey Questions

Personal Data from Users Who Are Financial Professionals

  • First & Last Name
  • E-Mail Address
  • Password
  • Bio
  • Answers to Survey Questions

Couplr uses an algorithm and other machine learning technology to match potential clients and financial professionals based on the supplied answers to the survey questions asked by the Couplr web application during sign up. While responses to the survey questions alone may not request Personal Data, Couplr will retain the answers to the survey questions keyed to a specific user for the purposes of suggesting matches.

IF YOU ARE CONCERNED ABOUT SHARING ANY OF THE ABOVE INFORMATION WITH COUPLR, DO NOT SIGN UP. SIGNING UP FOR A USER ACCOUNT WITH COUPLR SERVES AS YOUR EXPLICIT CONSENT TO SHARING THIS INFORMATION WITH THE COMPANY.

ACCESS TO AND CONTROL OVER INFORMATION

Under this Privacy Policy, a user has the following rights with regard to their Personal Data:

  • The Right to Know: Users can request information about the categories and specific pieces of Personal Data that Couplr has about them.
  • Right to Delete: Users can request that Couplr delete their Personal Data.
  • Right to Opt-Out of Sale\Sharing: Users can opt out of the sale or sharing of their Personal Data with third parties who are not users or Couplr.
  • Right to Correct: Users can request that Couplr correct any inaccurate Personal Data.
  • Right to Limit Use of Sensitive Personal Data: Users can limit the use of their sensitive Personal Data.

Financial professionals may access and update their Personal Data via the account portal on the Website.  Additionally, from the account portal, a Financial professional user can remove their Personal Data and cancel their account with Couplr.

All users may contact support@couplr.ai to update or change their Personal Data or exercise the rights detailed above. 

USE OF PERSONAL DATA COLLECTED

Couplr uses the Personal Data collected on the Website to allow Couplr to provide users with access to the Website, to provide potential matches between financial services professionals and those users seeking such services, and to ensure a user’s usage of the Website is in compliance with the Terms of Use and underlying licenses a user has signed (if any). Couplr may also use the Personal Data to contact a user for a variety of reasons, such as but not limited to notifying a user about use of the Website, offering additional products or services, or requesting feedback on the Website or its related services.

CAN-SPAM

Upon signing up with Couplr via the website, a user will be added to the Couplr mailing list. A user may opt-out of receiving further e-mails from Couplr (except for account related messages) following the directions at the bottom of each e-mail message, or e-mailing Couplr at support@couplr.ai.

DISCLOSURE OF PERSONAL DATA

When a potential match is made by Couplr – the financial services professional will receive a notification containing the name and profile photo (if any) of the user seeking financial services. Thereafter, the users may communicate together using Couplr’s integrated messaging platform, or share additional contact information and communicate on their own. Couplr is not responsible for any communication on or outside of the Website, and Users should share contact information at their own risk, and in their sole discretion.

Couplr may disclose Personal Data to third parties under certain circumstances. Couplr may disclose Personal Data to third parties:

  1. If a user has requested that Couplr do so;
  1. to comply with an applicable law, regulation, valid subpoena, or request of the US Government or;
  1. If Couplr is acquired by or merged into another entity, or all or a portion of Couplr’s assets are sold or otherwise transferred to another entity, Couplr may disclose Personal Data to that entity.

NON-PERSONAL DATA \ LARGE LANGUAGE MODELS

Non-Personal Data. Other data that does not qualify as Personal Data because it cannot be used to contact or identify users (“Non-Personal Data”) may also be automatically collected about a user utilizing the Website. For example, Couplr uses technology to automatically collect Non-Personal Data about the use of Website. This technology is used to track how many users access Website, the date and time of their visits, the length of their stays, and which pages they view. Couplr may also use technology to determine which web browsers users use and the address from which they accessed the Website. The information collected using this technology does not identify any user personally and is thus all Non-Personal Data that simply enables Couplr to compile statistics about users and their use of the Website and related services. Couplr uses this Non-Personal Data and may share it with third parties to improve the content and functionality of the Website, to better understand our customers and markets, and to improve our products and services.

Cookies.  Couplr may store certain information from a user’s web browser using “cookies.” A cookie is a piece of data stored on the user’s computer tied to information about the user. Couplr may use session-ID cookies to confirm that registered users are logged in. These cookies would terminate once the user closes the web browser. Couplr may also use persistent cookies that store certain Personal Data already provided to Couplr to make it easier for a user to log back into the Website. Cookies are used as a convenience feature for the user. A user can remove or block cookies using the settings in the user’s web browser if a user wants to disable such functions, but such action may impair the full functionality of the Website.

A Note about LLMs.  Couplr utilizes answers to a user’s survey questions and other Non-Personal Data to train its large language model and help determine the best ways to match potential users on the platform.  This information is anonymized and not tied to a specific user when the information is provided to the large language model and other artificial intelligence tools that Couplr maintains as part of its Website and related web application.

A Note about Google Analytics. Couplr utilizes Google Analytics to facilitate the collection of some Non-Personal Data. Google Analytics is subject to its own policies and by design, some Non-Personal Data collected by Google Analytics will be shared with Google. You can read more about the privacy practices of Google, and how the use of Google Analytics may impact a user’s use of the Website here: https://policies.google.com/technologies/partner-sites.

DO NOT TRACK SIGNALS

The Website does not track users over time and across third party websites to provide targeted advertising and, therefore, does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of browsing activities when they serve users content, which enables them to tailor what they present to different users. If a user is visiting such sites, a browser may allow users to set the DNT signal on that browser so that third parties (particularly advertisers) know that the user does not want to be tracked.

HACKING AND SECURITY

Couplr is SOC2 Level 2 Compliant as of 2025 and uses standard security measures to protect users’ Personal Data. While such security measures provide reasonable protections against unauthorized access, they provide no guarantee that Personal Data will not be compromised.

HACKING AND UNAUTHORIZED ACCESS OCCURS AND COUPLR PROVIDES NO GUARANTEE THAT PERSONAL DATA WILL NOT BE STOLEN OR MISUSED BY THIRD-PARTIES.

Whenever a website collects sensitive information (such as confidential business information), a user should confirm that the information is encrypted and transmitted in a secure way. One way that a user may do so is by looking for a closed lock icon at the bottom of the web browser, or looking for “https” at the beginning of the address of the web page.

DATA BREACH NOTIFICATIONS

In the event of a data breach that compromises the security, confidentiality, or integrity of Personal Data, Couplr will notify affected users as provided below.

  1. Notification Timing: Couplr will notify affected users without unreasonable delay, consistent with the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the integrity of Couplr’s Website and related application.
  2. Notification Method: Notifications will be made via email, mail, or other direct communication methods. If direct notification is not feasible due to cost, effort, or lack of contact information, a prominent posting on the Website or a notice via media channels may be used.
  3. Information Provided: The notification will include, to the extent possible:
    • A description of the breach.
    • The type of Personal Data compromised.
    • Couplr contact information for further inquiries.
    • Steps individuals can take to protect themselves from potential harm.
    • Couplr’s intended measures to rectify the breach and prevent future occurrences.

LINKS TO OTHER WEBSITES

The Website may contain web links to third-party websites. These websites are not under Couplr’s control. Couplr makes no representations or warranties as to the accuracy and information on or from other websites. Please be advised that the privacy policy and security policy of third-party linked websites are not that of Couplr.

QUESTIONS ABOUT OUR PRIVACY POLICY

If a user has any questions about this Privacy Policy or concerns about the way Couplr processes Personal Data, please contact Couplr at support@couplr.ai.

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