Privacy Policy

Policy Effective Date: September 28, 2026

Your trust is our priority, and we are working hard to protect your privacy. We will keep your information secure and confidential. We created this Privacy Policy to be as clear and direct as possible about how we gather and use your Personal Information.

This Privacy Policy explains how Personal Information is collected, used, disclosed, retained, and protected through our website located at www.unest.co, our UNest mobile application, our account services, and other products and services that link to this Privacy Policy (collectively, the "Services"). It also applies to artificial intelligence-enabled features offered through the Services, including the UNest AI Financial Guide powered by Bravo (the "AI Guide"). Additional notices may be presented when you use a particular feature. This Privacy Policy is a notice of our practices. Where applicable law requires consent for a particular use of Personal Information, we will request that consent separately. Our Terms & Conditions and, where applicable, your investment advisory, brokerage, insurance, or other account agreements govern your use of the applicable Services.

Personal Information Collected

We collect the following personal information from you:

• Contact information such as name, email address, mailing address, phone number
• Billing information such as credit card number and billing address
• Financial information such as bank or brokerage account numbers, types of investments
• Social Security number
• Username, account number, password
• Demographic information such as age, gender, and zip code
• When you download and use our Services, we automatically collect information on the type of device you use, the operating system version, and the device identifier
• Communications and support information, including emails, support requests, complaints, survey responses, and feedback
• AI Guide information, including prompts, questions, messages, selections, uploaded content, feedback, AI-generated responses, interaction metadata, relevant UNest profile or account information made available to the AI Guide, financial circumstances you choose to provide, and inferences such as likely financial goals, spending patterns, areas of financial interest, or potentially helpful educational topics

Do not enter passwords, authentication codes, full Social Security numbers, full payment-card numbers, private keys, or information about another person that you are not authorized to provide into the AI Guide. If you include sensitive information in a conversation, we will process it as part of that conversation as described in this Privacy Policy.

We may collect information about beneficiaries or dependents, including children, to establish, maintain, and service accounts, provide features you request, produce account statistics, and comply with applicable law. We disclose this information only as needed to provide and secure the Services, process information on UNest's behalf, comply with law, or as otherwise disclosed when the information is collected. We do not use beneficiary or dependent information to train general-purpose artificial intelligence models or for behavioral advertising.

Security

The security of your Personal Information is important to UNest. We maintain administrative, technical, and physical safeguards designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Our controls include measures appropriate to the nature of the information, such as access restrictions, encryption in transit and at rest where appropriate, logging, vendor oversight, and incident-response procedures. We may use financial information to establish, maintain, secure, and service your account; provide features you request; generate financial education and guidance through the AI Guide; comply with legal and regulatory obligations; and for the other purposes described in this Privacy Policy.

UNest takes reasonable steps to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables data transmission is ever fully secure or error-free; therefore, we cannot guarantee the security of any information you transmit to us.

Information Regarding Children

Due to the nature of our business, Services, and benefits are not marketed to minors. Except for beneficiary information as described above, UNest does not knowingly solicit Personal Information from children under the age of 18.

If you are under the age of 18, please do not submit any Personal Information to UNest. If we learn that we have collected Personal Information directly from a minor, we will remove such information from our files.

If a parent or guardian becomes aware that their child under the age of 18 has provided us with Personal Information without their consent, they should contact us at info@unest.co, and we will delete such information from our files.

We do not knowingly permit a person under 18 to use the AI Guide directly. The AI Guide should not be used to communicate with UNest on behalf of a child unless an authorized adult is using the adult's own account and has the right to provide the relevant information.

Other Ways We Collect Information

Other means by which we collect Personal Information include the following:

1. Anonymized or aggregated Information. UNest's Site and App automatically record certain information about your use or evaluation of our Service. Anonymized or aggregated information is used for many things, including measuring Users' interest in and using various site features. This information is not Personal Information, and we may use such information to analyze and research internally. In addition, we may share this information with third parties in an anonymized or aggregated form designed to prevent anyone from identifying you.
2. Cookies, Pixels, and Tracking. Like many digital platforms, UNest uses cookies, pixel tags (also known as web beacons), and other tracking technologies to understand how users interact with our website and mobile app. These tools help us improve functionality, performance, and user experience. Cookies are small text files placed on your browser that allow us to recognize repeat visits and track usage patterns. Pixel tags collect technical data such as IP address, device type, browser version, and interaction data (e.g., pages visited or buttons clicked).
3. We may also use third-party services that assist with usage analytics and product improvement. We configure these tools to avoid collecting sensitive user data where reasonably practicable. AI Guide prompts, responses, account information, and transaction information are processed only as described in this Privacy Policy and should not be captured by general analytics or session-replay tools unless expressly disclosed and legally permitted. You may be able to control or disable cookies through your browser settings. However, please note that some parts of the Services may not function properly without them.
4. Pixel Tags. Along with cookies, we may use "pixel tags," also known as "web beacons," which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
5. Site and App Activity. UNest may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site and App.
6. "Do Not Track" Technology. We do not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site does not respond to Do Not Track ("DNT") signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different websites or online services.

Artificial Intelligence-Enabled Features

The UNest Services may include an artificial intelligence-enabled conversational feature known as the "AI Financial Guide" or "Bravo" (the "AI Guide"). The AI Guide uses automated technologies, including generative artificial intelligence and large language models, to produce financial education and guidance. When you use the AI Guide, you are interacting with an automated system and not a human representative.

We may use AI Guide information to generate and personalize responses; use relevant account and transaction information to provide educational observations, estimates, explanations, and suggested next steps; maintain conversation context and preferences; detect and investigate fraud, abuse, security incidents, prohibited content, data leakage, and technical failures; test and improve the accuracy, safety, relevance, and performance of the AI Guide; provide support; investigate complaints; perform quality, compliance, supervisory, audit, and regulatory review; and create aggregated or deidentified analytics.

The AI Guide is not authorized to execute trades, move money, open or close accounts, purchase insurance, submit applications, or act on your behalf. We do not use the AI Guide to make final decisions about credit eligibility, insurance eligibility, employment, housing, or other decisions that produce legal or similarly significant effects.

Model Training and Product Improvement

We and our artificial intelligence model providers do not use identifiable AI Guide conversations, linked-account information, transaction information, beneficiary information, or dependent information to train general-purpose artificial intelligence models. Authorized personnel may use limited conversation samples to evaluate and improve the AI Guide for UNest, subject to access controls, confidentiality obligations, data-minimization measures, and applicable law. Where reasonably practicable, we remove or mask direct identifiers before such evaluation.

Human Review

Authorized personnel of UNest and its service providers may review a limited number of AI Guide conversations and related records when reasonably necessary to provide support; investigate a complaint, suspected fraud, security concern, or technical issue; test and improve the AI Guide; perform quality, safety, supervisory, or compliance review; or comply with legal, audit, recordkeeping, or regulatory obligations. Access is limited according to role and purpose and is subject to confidentiality and security controls.

Product Personalization and Marketing

We do not use the content of identifiable AI Guide conversations or inferences derived from those conversations for behavioral advertising, third-party advertising, advisor lead generation, product-opportunity scoring, or targeted solicitation of investment, insurance, credit, or other financial products. We may use conversation topics to personalize the educational response you request and determine whether human support is needed for a complaint, suspected fraud, account instruction, security concern, or other matter requiring attention.

AI Guide Service Providers

UNest uses Ovation Ventures, Inc. ("Ovation") to provide, operate, manage, monitor, and support the Bravo AI Financial Guide on UNest's behalf. Depending on how the service is configured, Ovation and its authorized service providers may process prompts, relevant UNest account and transaction information, AI-generated responses, feedback, and technical and security logs.

Ovation acts as a service provider to UNest and may process this information only for authorized purposes, including operating, securing, evaluating, supporting, and improving the AI Guide for UNest. UNest does not permit Ovation or its authorized service providers to sell the information, use it for their own advertising, or use identifiable UNest customer information to train general-purpose artificial intelligence models.

Privacy requests relating to the AI Guide should be directed to UNest at support@unest.co. Ovation processes such requests on UNest's instructions where applicable.

AI Guide Retention and Deletion

We may retain AI Guide conversations, responses, related account context, derived information, and technical records for as long as reasonably necessary to provide conversation history, maintain security, provide support, perform compliance and supervisory review, resolve disputes, and satisfy legally required books and records. Retention periods may differ by record type and legal obligation.

You may request deletion of eligible AI Guide information by contacting support@unest.co or using any deletion control UNest makes available. UNest may retain information when required or permitted by law, including for securities recordkeeping, fraud prevention, security, dispute resolution, and enforcement of agreements. Deleting a conversation from the visible interface may not immediately delete records from backups or records that UNest is legally required to retain.

User Personal Information

We use your Personal Information to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your Personal Information in a number of ways, including research, internal analysis, and analytics.

Client Personal Information

UNest stores, processes, and maintains Personal Information related to you in order to provide client support, offer new products or services, and provide our Services to clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the "SEC") and Financial Industry Regulatory Authority, Inc. ("FINRA"). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a client.

Additionally, we may share the information required to become a client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide services to you.

Mobile Computing

UNest provides websites and online resources specifically designed to be compatible with and used on mobile computing devices. Mobile versions of our Site may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download an application, widget, or other tools that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools can and may transmit Personal Information to UNest to enable you to access your account information and to enable us to track the use of these tools. Some of these tools may allow users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Privacy Policy or in other notices we provide.

Information Sharing and Onward Transfer

We will not sell, rent, or trade your Personal Information (whether you are a current or former client) to any non-affiliated third parties without your permission except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, or situations involving potential threats to the physical safety of any person.

In certain circumstances, we may share your Personal Information with non-affiliated third parties without further disclosure to you. For example, we hire third parties from time to time to perform particular business and technology-related functions (e.g., mailing information, database maintenance, and payment processing). If we hire a third party to perform a function of this kind, we aim to only provide them with the minimum information they need to perform their specific function and to require these third parties to safeguard your Personal Information.

Your Choices and Opting Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

You may decline to provide Personal Information to UNest. However, declining to provide Personal Information may disqualify you from UNest services and Site features that require certain Personal Information.

Opting-Out – Obtaining and Withdrawing Consent

Where you have consented to UNest's use of your Personal Information, you may withdraw that consent at any time and opt out by contacting us via the email address indicated in the Contact Information Section below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and allow you to opt-out.

Before disclosing sensitive Personal Information to a third party or processing sensitive Personal Information for a purpose other than its original purpose or the purpose authorized subsequently by you, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, we will have to comply with the aforementioned law or contract.

We will only use Employee Personal Information for employment-related purposes. If we intend to use this Employee's Personal Information for any other purpose, we will provide the Employee with an opportunity to opt out of these uses.

Retention and Deletion

UNest retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Sites or App or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

You may request the deletion of Personal Information by contacting us at support@unest.co and providing us with enough information to identify your account and prove that you are the owner of the specified account. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. We will not share any personal trading data unless regulators or other government bodies require it.

California Privacy Rights

California law permits Users and Clients who are California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. UNest does not share Personal Information with third parties for its own marketing purposes.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our practices. If we make changes, we will notify you by email or by means of a notice on our website or mobile app before the change becomes effective. We encourage you to review this page periodically for the latest information on our privacy practices.

We will not rely solely on a policy update to apply materially broader AI training or third-party data-use practices retroactively to Personal Information collected under a conflicting prior promise. We will provide additional notice and obtain consent when required by applicable law.

Contact Information

Do not hesitate to contact UNest with any questions or concerns about our Privacy Policy at support@unest.co. We want you to feel completely safe using our services, so we encourage communication on both ends.