Givest Privacy Policy

Effective date: Winter 2026 (launch)

Givest helps people give real stock as a gift. This policy explains what information we collect, why we collect it, who we share it with, and the choices you have. We wrote it to be read.

Some quick facts up front:

• We do not sell your personal information.
• We do not run ads in Givest and we do not share your information for advertising.
• We collect what we need to run a regulated financial service, and we keep what the law requires us to keep.

1. Who we are

Givest is operated by Givest Technologies, Inc. Investment advisory services are provided by Givest Advisors, Inc., an investment adviser registering with the U.S. Securities and Exchange Commission. Brokerage services are provided by Alpaca Securities LLC, a registered broker-dealer and member of FINRA and SIPC. Gift funds in transit are held in a custody account for the benefit of Givest customers at Cross River Bank. In this policy, "Givest," "we," and "us" refer to Givest Technologies, Inc. and Givest Advisors, Inc. together.

As financial institutions, we are subject to federal privacy laws that apply to financial information, including the Gramm-Leach-Bliley Act and SEC Regulation S-P. This policy also serves as the privacy notice those laws require.

2. Information we collect

Information you give us.

• Account information: name, email address, and password, or your Google or Apple sign-in.
• Identity verification information: legal name, date of birth, Social Security number, residential address, and phone number. Federal law requires us to collect this to open a brokerage account. It is collected when you claim a gift or open an account, and it is transmitted to Alpaca Securities LLC to verify your identity and open your account. Your Social Security number is not stored on Givest's systems: it passes through to the broker-dealer and is not written to our databases or our logs.
• Custodial account information: if you open a custodial account for a minor, we collect the minor's legal first and last name, date of birth, state of residence, email address, and Social Security number, provided by you as the custodian. Federal law requires this to open a brokerage account for the minor. Like your own identity information, it is transmitted to Alpaca Securities LLC to verify identity and open the account, and the minor's Social Security number is not stored on Givest's systems.
• Bank account information: when you connect a bank account, you do so through Plaid. We receive tokens and account metadata (such as institution name and account mask). We do not receive or store your bank username or password.
• Gift information: the amount, the stock suggestion, the recipient's name and email address, and any personal message you attach.
• Communications: messages you send to support and responses you give us.

Information we collect automatically.

• Technical information our servers receive: your IP address, device type, operating system, and app version, which arrive with the requests your app and browser make. We use this to operate, secure, and troubleshoot the service. We do not use analytics software, and we do not record which screens you view or which actions you take inside the app. If that ever changes, we will update this policy before it changes, through the material-change notice described in Section 10.
• Transaction records: gifts created, claimed, and completed, deposits, and account activity. These are the books and records of a financial service.

Information we receive from others.

• From Plaid: bank account connection status and account metadata.
• From Alpaca Securities LLC: identity verification results, brokerage account status, positions, and account activity.
• From our payment providers and partner bank: payment status and transfer records for gift funds.

We do not collect precise location. We do not collect biometric data. We do not buy data about you from data brokers.

3. How we use information

• To provide the service: create and deliver gifts, open brokerage accounts, move gift funds, show you your portfolio, and send the emails that the service requires (claim links, confirmations, refund notices, account notices).
• To meet legal obligations: identity verification, books and records, tax reporting, responding to lawful requests, and the compliance obligations of a registered investment adviser.
• To keep the service safe: detecting fraud and abuse, securing accounts, and monitoring the reliability of the service.
• To improve the service: understanding how features are used, fixing defects, and making Givest better.
• To communicate with you about your account. We send transactional email through our email provider. Marketing email, if we ever send it, will always include an unsubscribe link.

4. How we share information

We share personal information only in these circumstances:

• Service providers who help us run Givest. These include Alpaca Securities LLC (brokerage and identity verification), our payment infrastructure providers and Cross River Bank (moving and holding gift funds), Plaid (bank account connection), our cloud hosting, authentication, and email delivery providers, and our compliance and communications archiving providers. Each receives only what it needs to do its job and is bound by contractual confidentiality and data protection obligations.
• As required by law. We disclose information when required by subpoena, regulation, examination by a regulator such as the SEC, or other lawful process, and to protect the rights, safety, and property of Givest, our users, or others.
• Corporate transactions. If Givest is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this policy's commitments.
• With your direction. For example, the recipient of your gift sees your name, the gift amount after they reveal it, and your message.

We do not sell personal information. We do not share personal information with third parties for their own marketing. We do not share personal information with nonaffiliated third parties outside the purposes above, which means federal law does not require us to offer an opt-out, because there is nothing to opt out of.

5. How we protect information

We maintain administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest, multi-factor authentication on production systems, access logging, and vendor security oversight. We maintain a written incident response program as required by SEC Regulation S-P. If we determine that your sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization, we will notify you within 30 days as Regulation S-P requires.

No system is perfectly secure, and we cannot guarantee the security of information. Please use a strong, unique password and protect your sign-in credentials.

6. How long we keep information

We are required by SEC Rule 204-2 to keep the books and records of our advisory business for at least five years, and in some cases longer. That includes transaction records, account records, and communications relating to gifts, funds, and securities.

When you request account deletion, we will close your account, end our active use of your information, and delete or de-identify information that we are not required to keep. Records that the law requires us to retain, such as transaction history, identity verification records, and required communications, are retained for the legally required period with access restricted, and are then disposed of securely.

7. Your choices and rights

• Access and correction. You can view and update your profile information in the app. For anything you cannot change yourself, contact us.
• Account deletion. You can request account deletion in the app (Account, then Delete your account) or on the web at givest.app/account/delete. We will confirm by email when your request is complete. Deletion is subject to the legal retention obligations described above, and to the completion of any gift that is still in flight.
• Email. Transactional emails (claim links, confirmations, required notices) are part of the service. Any marketing email will include an unsubscribe link.
• State privacy rights. Depending on where you live, you may have rights under state privacy laws to access, correct, delete, or obtain a copy of your personal information, and to not be discriminated against for exercising those rights. Much of the information we hold is financial information covered by federal law (the Gramm-Leach-Bliley Act) and is exempt from many state privacy laws, but where state rights apply, you can exercise them by contacting privacy@givest.app. We will verify your identity before acting on a request. We do not sell or share personal information for cross-context behavioral advertising, so there is nothing to opt out of under those laws.

8. Children's privacy

Givest is for adults. You must be 18 or older to create a Givest account. Custodial accounts for minors are opened and controlled by an adult custodian; the minor's information described in Section 2 is provided to us by the custodian, and the brokerage account is opened for the minor's benefit under applicable custodial account law (UGMA/UTMA). We do not knowingly collect personal information online from children under 13. If you believe a child has provided us personal information directly, contact us at privacy@givest.app and we will delete it.

9. Where Givest operates

Givest is designed for people in the United States. Our service providers process information in the United States. If you use Givest from outside the United States, you understand your information will be processed in the United States.

10. Changes to this policy

When we make material changes to this policy, we will notify you in the app or by email before the changes take effect, and we will update the effective date above. Earlier versions will be available on request.

11. Contact us

Questions about privacy, or requests under this policy:

• Email: privacy@givest.app
• Support: support@givest.app
• Mail: Givest Technologies, Inc., Kansas City, MO

If you have a concern we have not resolved, you may also contact your state regulator or the U.S. Securities and Exchange Commission.