Clink

CLINK SAVINGS INC.
PRIVACY NOTICE AND POLICIES

The privacy polices (collectively the "Policy") set forth herein were developed as an extension of our commitment to combine high quality products and services with the highest level of integrity in dealing with our clients and partners. This Privacy Notice is designed to assist you in understanding how we collect, use and safeguard the non-public personal information ("Information") client's provide to us and to assist you in making informed decisions when using our website and our products and services.

This Privacy Notice will be continuously assessed against new technologies, business practices and our clients' needs and may be updated by us from time to time as required and such changes shall be binding on you. By using our services you consent to our collection of your Information and the Policy as described in this Privacy Notice. This Privacy Notice and all changes to it shall be at all times published on our website for your review. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Clink Savings Inc. Services Agreement.

In connection with the services that we provide we receive and collect, by way of example and not limitation, client Information as follows: (i) from clients pursuant to the terms and conditions of our Services Agreement and email and voice communications with and from clients related thereto; (ii) from Apex and other third party financial services providers with whom clients' have given us permission to communicate and interface ("Authorized Third Parties"); (iii) with regard to the records of client transactions with and through us; and (iv) as otherwise voluntarily provided by clients via our website and apps.

We only use Information for purposes of administering client accounts, interfacing with Authorized Third Parties and providing product and customer services to our clients. Except as set forth in the last sentence of this paragraph, we do not disclose Information to any third parties other than the Authorized Third Parties and our financial advisors, attorneys and other professional advisors with a need to know in order to advise us and to assist us to provide services to our clients and provided they are bound by either an agreement with us to protect the confidentiality of the Information or a professional code of responsibility to do so. We will release Information about a client if we are directed to do so by such client or if we are legally compelled to do so in our good faith determination in order to protect our legal rights and interest, but in doing so we will take reasonable action to require the receiving third party to treat the disclosed Information as confidential.

We utilize electronic, physical and process and procedure safeguards as well as encryption/security software to protect the confidentiality of the Information we collect from unauthorized access or disclosure, and we restrict access to the Information to our employees and other persons with a need to know in order to assist us to provide services to our clients.