Legal

Privacy Policy

What does Monorail do with your personal information

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Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

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What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

▪ Social Security number and/or Employer Identification Number (EIN)

▪ Account balances and financial account information

▪ Subscription book certifications (for accreditation determinations)

▪ Date of Birth

▪ Sources and Amounts of Income

▪ Telephone Numbers

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How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Monorail chooses to share; and whether you can limit this sharing.

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Reasons we can share your personal information

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For our everyday business purposes –

such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

‍Does Monorail share Yes‍
Can you limit the sharing No

For our marketing purposes –

‍to offer our products and services to you

‍Does Monorail share Yes‍
Can you limit the sharing Yes

For joint marketing with other financial companies

‍Does Monorail share No
Can you limit the sharing We don't share

For our affiliates’ everyday business purposes –

‍information about your transactions and experiences

‍Does Monorail share No
Can you limit the sharing We don't share

For our affiliates’ everyday business purposes –

‍information about your creditworthiness

‍Does Monorail share No
Can you limit the sharing We don't share

For our affiliates to market to you

‍Does Monorail share Yes
Can you limit the sharing No

For our nonaffiliates to market to you

‍Does Monorail share No
Can you limit the sharing We don't share

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Questions privacy@monorail.com

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Who we are

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‍Who is providing this notice Monorail Financial, LLC, a Florida limited liability company doing business as Monorail.

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What we do

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How does Monorail protect my personal information To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

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How does Monorail collect my personal information We collect your personal information, for example, when you
▪ Open an account
▪ Contact us
▪ Engage in transactions with us
▪ Give us your contact information or provide account information
We also collect your personal information from other companies.

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Why can’t I limit all sharing Federal law gives you the right to limit only
▪ sharing for affiliates’ everyday business purposes – information about your creditworthiness
▪ affiliates from using your information to market to you
▪ sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

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Definitions

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Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
▪ Monorail Financial Holdings, LLC is the parent firm to the following affiliated entities: Monorail Securities LLC (“Monorail Securities”), Monorail Financial, LLC d/b/a Monorail, and Monorail IP, LLC.

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Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
▪ Nonaffiliates we share with can include financial institutions, service providers, investment accreditation services.

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Joint Marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.
▪ Monorail doesn’t jointly market.

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Other Important Information

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California and Vermont Residents: We will not share information we collect about you with companies outside of Monorail (including with our affiliates) except as permitted by law and as described in this Privacy Policy.

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MONORAIL PRIVACY POLICY

Effective Date / Date of Last Revision: October 24, 2023

NOTE: OUR WEBSITE, APP AND SERVICES ARE INTENDED ONLY FOR USE BY ADULT INDIVIDUALS WITHIN THE UNITED STATES. IF YOU ARE NOT LOCATED WITHIN THE UNITED STATES, PLEASE REFRAIN FROM CREATING AN ACCOUNT OR SENDING PERSONAL DATA TO US.

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1. WHO WE ARE.

2. HOW TO CONTACT US.

3. WHY AND HOW WE COLLECT DATA.

4. PROTECTING YOUR PRIVACY GENERALLY.

5. DOWNLOADING THE APP.

6. CHILDREN’S PRIVACY.

7. TYPES OF INFORMATION WE COLLECT.

8. DO NOT TRACK SIGNALS.

9. HOW WE USE YOUR PERSONAL DATA.

10. INFORMATION WE SHARE WITH THIRD PARTIES.

11. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA.

12. SECURITY.

13. DATA RETENTION.

14. ACCESSIBILITY.

15. NOTICE TO NEVADA RESIDENTS.

16. NOTICE TO CALIFORNIA RESIDENTS.

17. CHANGES TO THIS POLICY.

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1. WHO WE ARE.

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Monorail Financial, LLC, is a Florida limited liability company doing business as Monorail (“Monorail,” “we,” “our” or “us”) has developed and offers proprietary investment tools and accounts made available via downloadable app and Monorail’s website, https://monorail.com (collectively referred to as the “App”). Monorail is a Registered Investment Advisor (“RIA”) with the Securities and Exchange Commission (“SEC”). As an RIA registered with the SEC, Monorail is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and the SEC’s Privacy of Consumer Information Rule (“Regulation S-P”). Through the App, we provide information and tools for financial planning, investing, stock trading, (“Services”). When providing our App and Services, we collect data from our App users.

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Some of the data we collect may be considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”). Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual. It does not include deidentified or anonymized data.

The purpose of this Privacy Policy is to plainly and transparently disclose to you how we collect, use and share information, and how we attempt to safeguard the data you provide to us. We are committed to securing data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws.

Please note that if you have entered into any other agreements with Monorail or its affiliates, this Privacy Policy will not amend, revise, or otherwise change the terms and conditions contained in those agreements, including any privacy obligations you might have under those agreements.

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2. HOW TO CONTACT US.

If you have any questions regarding data protection or your rights, please contact us:

Monorail

3322 Bee Ridge Road

Sarasota, FL 34239

privacy@monorail.com

Contact webform

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3. WHY AND HOW WE COLLECT DATA.

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We collect, process and use Personal Data to allow you to utilize the functionality and features we provide through our App, to provide you with Services, and to communicate with you. The legal basis for our collection of Personal Data is with your consent, for our legitimate business purposes and/or to comply with our legal and contractual obligations. We obtain Personal Data directly from you, through cookies and other technologies, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.

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a. Information from you. You provide data directly to us when you directly submit information to us (for example, when you register for an account, sign up for Services, enter into transactions though the App, and send us information through a contact form).

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b. Cookies & Technology. We collect data by automatically recording how you interact with our App using technologies like cookies. More information on cookies is provided below.

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c. Information from our service providers. We collect data from our services providers who support our App and/or Services. More information on our services providers is provided below.

4. PROTECTING YOUR PRIVACY GENERALLY.

a. Industry-Standard Protection. We utilize industry-standard security measures to safeguard the information we collect, maintain and use. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration or destruction. However, we do not guarantee the performance or adequacy of such security measures.

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b. Limitation on Access. Access to any Personal Data we collect and store is generally restricted to our employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry standard protocols to maintain the confidentiality, security, and integrity of Personal Data.

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5. DOWNLOADING THE APP.

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We make our App available through third-party application stores, such as the Google Play Store and the Apple App Store. Monorail assumes no responsibility for the collection or processing of data by Google, Apple or any other app store provider at the time of downloading the App or creating an account with such app store providers. Please refer to the data privacy statements and terms of use of these providers to understand how they may collect, use, process, store and share your data. There is no exchange of data between us and the app store providers.

6. CHILDREN’S PRIVACY.

We do not intentionally collect any Personal Data from children under the age of eighteen (18). We do not sell the Personal Data of children under the age of eighteen (18). If you believe that a child under the age of eighteen (18) has provided us with Personal Data, please contact us at privacy@monorail.com so that we can delete it or obtain verifiable parental consent for that data collection.

7. TYPES OF INFORMATION WE COLLECT.

a. Information we collect from you. We collect the following categories of Personal Data:

Contact information (name, local and permanent address, telephone number, electronic mail address).
Your date of birth.
Your social security number or your Employer Identification Number.
Your country of domicile.
Your financial account information.
Your financial transaction information.
Any other information you provide to us.

b. Information We Collect Via Tracking Technology. We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”) to collect information as you navigate our App. Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

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We use Cookies to: (a) estimate audience size and usage patterns; (b) understand and save your preferences for future visits, allowing us to customize the online experience to your individual needs; (c) advertise new content, events and services that relate to your interests; (d) keep track of advertisements and search engine results; (e) compile aggregate data about App traffic and interactions to resolve issues and offer better online experiences and tools in the future; and (f) recognize when you return to our App.

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The Cookies we use collect the following types of Personal Data:

Usage Information. We collect information such as which areas and features of the App you access, the frequency of access, and what you click on while using the App.
Technical Information. We collect technical information about your connection to our App, including the Internet protocol (IP) address, browser type and version, browser plug-in types and versions.
Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number.
Mobile Device Information. In addition to the device information listed above, when you access our App on your mobile device, we collect and aggregate information about whether you are accessing the App via mobile device or tablet, device type, and carrier.
Location Information. We collect and store IP addresses, so we collect geolocation data, but not precise location data.

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We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our App, to conduct advertising, and to analyze the effectiveness of advertising.

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Google Analytics

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We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the App and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

c. How To Opt-Out of Cookies & Learn More. Cookies can be blocked by changing your settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the App. You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org. You can also learn about which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website, Your Ad Choices, Your Online Choices and Global Privacy Control.

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8. DO NOT TRACK SIGNALS.

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Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the App does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

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9. HOW WE USE YOUR PERSONAL DATA.

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We use the Personal Data we collect to:

Communicate with you;
Provide you with information;
Provide our Services;
Provide support;
Improve our Services;
Maintain and improve our App;
Defend our legal rights and the rights of others;
Efficiently maintain our business;
Comply with applicable law; and
For any other reason with your consent.

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10. INFORMATION WE SHARE WITH THIRD PARTIES.

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We do not sell personal data. We may share the information that we collect about you in the following limited ways:

a. With Service Providers. We may share information with service providers who:

Provide Services on our behalf, such as financial transactional Services. Examples include: Orbis Systems, Inc., Plaid Inc., ViewTrade Securities, Inc., Cboe Global Markets, Inc. and United Charitable Programs.
Provide information technology services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.). Examples include: Cloudinary Ltd., Apple Inc., Alphabet Inc., Microsoft Corporation, Bugsee, Inc., Intercom and Zendesk, Inc.
Prepare, deploy and analyze advertising content on our behalf. Examples include: AppsFlyer Inc., Iterable, Inc., Mixpanel, Inc., Segment.io, Inc.
Provide push notifications to you. Example includes: OneSignal.
Process transactions on our behalf. For example, the App uses technology from Plaid to gather data from financial institutions. By using the App, you grant Monorail and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy, which is currently available at https://plaid.com/legal/#end-user-privacy-policy.
Provide other services on our behalf, such as accounting services, and other various services.

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b. To Meet Our Legal Requirements or Exercise Our Rights. We may share information with third parties in the following instances:

When we are required to do so by law.
In connection with any legal proceedings or prospective legal proceedings.
To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
When we reasonably believe it is appropriate to apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal data.
We may share information with other persons or entities as part of our own corporate transactions, such as during financing or any asset sale.

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11. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA.

We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties.

You may decline to provide information. You have the right to decide not to share information with us.

Request deletion. You may submit a request to update or delete your personal data by contacting us at us at privacy@monorail.com.

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PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE NOT TO PROVIDE US WITH CERTAIN INFORMATION OR ASK US TO DELETE YOUR INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH SOME OF OUR SERVICES OR APP FUNCTIONALITY. IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.

Review and request changes to your personal data. You may use your account to access, correct, or view certain personal data we have collected which is associated with your account. You may also contact us at privacy@monorail.com to request information or changes.

Marketing communications. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls and postal mail. To do so, contact us at privacy@monorail.com.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Data with unaffiliated or non-agent third parties for advertising, marketing, or promotional purposes, you can opt-out by sending us an email with your request to privacy@monorail.com.

Control Cookies. You may opt out of cookies through your account settings in the App or as described in Section 7 (c) above.

12. SECURITY.

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When you register for an account with us, you will be required to choose or will be assigned a password which enables you to access our App and Services. You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone. If your password is compromised, change your password within your account. If you believe your password or account may have been compromised, please notify us immediately.

We take industry standard security measures to protect your information. We also have put into place appropriate agreements and/or procedures with our service providers to ensure that your Personal Data is treated consistent with applicable data privacy and security laws. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot and do not guarantee the security of your data.

13. DATA RETENTION.

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We will store your Personal Data for as long as: (a) you maintain an account with us; (b) you continue using our App and Services; (c) your Personal Data is stored in our back up servers and/or services; (d) in accordance with our retention policies and schedules; and (e) as long as we are legally required to retain the Personal Data.

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14. ACCESSIBILITY.

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing, please email us at privacy@monorail.com. You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.

15. NOTICE TO NEVADA RESIDENTS.

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to privacy@monorail.com.

16. NOTICE TO CALIFORNIA RESIDENTS.

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide certain rights to California residents regarding the collection, use, disclosure, and sale of personal information. As of the date of last revision of this Privacy Policy, we were not / are not subject to the requirements of the CCPA or CPRA. If this changes, we will update our Privacy Policy. In the interim, of you would like to contact us to access and control your Personal Data, please see the options and tools we provide in Section 11 above and feel free to contact us with any questions.

SHINE THE LIGHT LAW: If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). We do not sell or disclose information to third parties for their direct marketing purposes.

17. CHANGES TO THIS POLICY.

We will update this Privacy Policy from time to time as our data collection processes change and/or as required by applicable law. You are responsible for monitoring this Privacy Policy periodically for changes. If you do not agree to the terms of this Privacy Policy, do not use our App or Services.

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