Privacy Policy

1. Introduction and scope

Freedom Financial Plus Inc. d/b/a FreedomPath ("FreedomPath," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect Personal Information and describes choices and rights that may be available to you.

This Policy applies to Personal Information we process through freedompath.com; our mobile applications; Independent Broker websites, portals, and replicated websites that we operate or control; our products and services; customer support; communications; events; and other online or offline interactions that link to or reference this Policy (collectively, the "Services").

This Policy does not apply to a third party's own services or practices, even when a third-party service is linked from or integrated with our Services. It also does not apply where a separate notice governs, such as a workforce/applicant notice, a product-specific notice, or a financial privacy notice provided under applicable financial-privacy law. If another notice conflicts with this Policy, the more specific notice controls for the information and activity it covers.

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household. It includes "personal data," "personal information," and similar terms under applicable privacy laws. It does not include information excluded by law, such as certain lawfully public or properly deidentified information.

2. Personal Information we collect

The information we collect depends on your relationship with FreedomPath, the Services you use, and the choices you make. We may collect the categories below. A category is included only to describe information actually processed for the stated purposes; FreedomPath must remove any category that its verified data map shows it does not process.

A. Identifiers and contact information

Name, alias, date of birth, mailing or physical address, email address, telephone number, account or customer number, broker or member identification number, online identifiers, IP address, device identifiers, username, and similar identifiers.

B. Account and authentication information

Username, encrypted or otherwise protected password or authentication data, account settings, security questions, login activity, authentication tokens, and records used to secure or administer an account. We do not disclose account passwords in response to access requests.

C. Government and tax identifiers

Social Security number, taxpayer identification number, driver's-license or other government-issued identifier, and tax documentation, when needed for broker onboarding, payments, compliance, fraud prevention, or another disclosed lawful purpose.

D. Financial, payment, credit, and transaction information

Payment-card or bank information, billing details, payment status, purchases, subscriptions, refunds, commissions, earnings, account balances, credit-related information, identity-monitoring information, consumer-report information where legally permitted, and related transaction records. Payment information may be tokenized or processed directly by a payment provider.

E. Commercial and relationship information

Products or services considered, purchased, or used; membership and subscription information; customer-service history; preferences; contest or survey participation; referrals; broker sponsorship and organizational relationships; and sales, purchase, recruitment, commission, and downline activity.

F. Internet, device, and electronic activity

Browsing and search activity on the Services, referring and exit pages, pages or features viewed, clicks, session activity, timestamps, device and browser type, operating system, mobile carrier, application version, cookie and pixel identifiers, advertising identifiers, approximate location derived from IP address, email opens, and interactions with our communications and advertisements.

G. Location information

Approximate location and, only where enabled and legally permitted, precise geolocation.

H. Communications and content

Emails, text messages, call records and recordings where permitted, chat or support messages, survey responses, reviews, comments, uploaded documents, forum posts, public-profile information, and other content you provide.

I. Professional, education, and broker information

Employment or business history, licenses, qualifications, training, certifications, background or eligibility information, business performance, and information used to establish or manage an Independent Broker relationship.

J. Inferences and profiles

Preferences, interests, likely product interests, fraud or security risk indicators, engagement predictions, and other inferences created from information described in this Policy.

K. Sensitive Personal Information

Depending on the Service and as permitted by law, this may include government identifiers; account credentials; financial information; precise geolocation; and the contents of communications when FreedomPath is not the intended recipient. We use Sensitive Personal Information only for disclosed and legally permitted purposes and obtain consent where required.

L. Other information you provide

Any other Personal Information you choose to provide or that we collect with your consent or as otherwise permitted by law.

3. Sources of Personal Information

We collect Personal Information from the following sources:

• Directly from you, including through registrations, applications, purchases, forms, communications, surveys, promotions, and support interactions.
• Automatically from browsers, devices, applications, cookies, pixels, SDKs, logs, and similar technologies when you use or interact with the Services or communications.
• From Independent Brokers, including a sponsoring broker or a broker assisting you with enrollment, a product, or support.
• From affiliates and business partners involved in products or services you request.
• From payment processors, banks, card networks, delivery providers, identity-verification providers, insurers, credit or consumer-reporting sources where legally permitted, fraud-prevention providers, and similar service providers.
• From advertising, analytics, lead-generation, social-media, and communications providers.
• From data providers, public records, government agencies, and other lawfully available sources.
• From corporate transactions, acquired businesses, and successor organizations.

4. How we use Personal Information

We may use Personal Information for the following purposes, subject to applicable law and any more specific notice:

• Provide, administer, personalize, and improve the Services; process transactions, subscriptions, deliveries, and payments; maintain accounts; and provide support.
• Verify identity, authenticate users, prevent account takeover, detect fraud, protect consumers, secure the Services, and investigate misuse or incidents.
• Administer memberships and Independent Broker relationships, including enrollment, sponsorship, training, commissions, tax reporting, compliance, lead routing, and organizational or genealogy reporting.
• Communicate about accounts, transactions, products, services, policy changes, safety, and support.
• Send marketing, promotional email, or text messages where permitted; measure engagement; and honor opt-outs and consent withdrawals.
• Analyze use, troubleshoot, conduct research, test features, measure performance, and develop or improve products and services.
• Select, deliver, measure, and understand advertising, including targeted advertising only where permitted and subject to required choices.
• Comply with law, licenses, regulatory requests, legal process, audits, tax obligations, and contractual requirements; establish, exercise, or defend legal claims.
• Conduct corporate transactions such as financing, acquisition, reorganization, bankruptcy, or sale of assets.
• Create aggregated or deidentified information. Where required, we will maintain such information in deidentified form and will not attempt to reidentify it except to test whether deidentification measures are effective.
• Fulfill another purpose disclosed when information is collected, with your direction or consent, or as otherwise permitted by law.

We do not use Sensitive Personal Information to infer characteristics about you except as disclosed and permitted by law. We do not collect or process more Personal Information than reasonably necessary and proportionate for the disclosed purposes.

5. Cookies, analytics, and online advertising

We and our vendors may use cookies, pixels, tags, SDKs, local storage, advertising identifiers, and similar technologies to operate the Services, remember preferences, maintain sessions, measure performance, understand communications, prevent fraud, and support advertising. These technologies may collect identifiers, device information, browsing activity, approximate location, and interactions over time and across websites, applications, browsers, or devices.

Some technologies are necessary for requested functionality. Where required, we obtain consent before using nonessential technologies. You may manage choices through browser or device settings, or the privacy choices described below. Blocking technologies may affect functionality, but we will not state that you assume responsibility for resulting loss.

Depending on our verified advertising and analytics configuration, disclosures to advertising or analytics partners may be considered a "sale," "sharing," or processing for targeted advertising under certain state laws even when no money changes hands. We do not sell/share Personal Information as those terms are defined by applicable law.

Where required, we honor opt-out preference signals such as Global Privacy Control as a request to opt out of sale or sharing for the browser or device sending the signal. Cookie controls and opt-outs are device- and browser-specific unless we can associate them with your account.

6. How we disclose Personal Information

We may disclose Personal Information to the categories of recipients below for the stated purposes. We do not disclose information merely because a category is listed; disclosures must be supported by our verified practices and appropriate contracts.

Service providers and processors

Hosting, cloud, cybersecurity, identity-verification, payment, billing, fulfillment, delivery, communications, customer support, data management, analytics, auditing, professional-services, and other vendors that process information for us under contractual restrictions.

Affiliates and product partners

Affiliated entities and partners involved in providing, administering, supporting, or marketing products and services, consistent with applicable law and required choices.

Independent Brokers

If you interact with, enroll through, sponsor, or are assigned to an Independent Broker, we may provide relevant contact, account, product-interest, enrollment, or support information to that broker. For network administration, an Independent Broker's name, contact information, sales, purchase, recruitment, and organizational activity may be available to the sponsoring broker and authorized upline brokers through access-controlled systems. Brokers must use this information only for authorized purposes and under applicable agreements. A broker may independently control information the broker collects outside systems or activities controlled by FreedomPath; contact that broker regarding the broker's independent practices.

Payment, financial, identity, credit, and insurance providers

Providers involved in transactions, credit-building or monitoring, identity protection, insurance, funding, eligibility, compliance, fraud prevention, collections, or services you request. Applicable financial or consumer-reporting notices may provide additional detail.

Advertising, analytics, and social-media partners

Partners that measure use or campaigns, provide social features, or help deliver advertising, subject to consent and opt-out rights. Their independent processing is governed by their notices.

Legal, safety, and compliance recipients

Courts, law enforcement, regulators, tax authorities, licensing bodies, auditors, advisers, and other parties when reasonably necessary to comply with law or legal process; protect rights, safety, property, or security; prevent fraud or abuse; or establish, exercise, or defend claims.

Corporate transaction parties

Potential or actual buyers, sellers, lenders, investors, advisers, successors, or other parties in connection with due diligence, financing, merger, acquisition, reorganization, bankruptcy, or transfer of assets, subject to appropriate safeguards.

At your direction or with consent

Other recipients when you direct us, intentionally make information public, request an integration or referral, or provide legally valid consent.

7. Independent Broker and referral features

Lead assignment and locator features may provide a prospective customer's or broker's contact and inquiry information to an appropriate Independent Broker and may provide the broker's contact information to the prospect. Referral or "invite a friend" functions may send a communication identifying you as the referrer. You must have authority to provide another person's contact information and should not use referral features for unsolicited communications.

Information posted to a public profile, forum, review, message board, or similar public feature can be viewed, copied, or used by others. Do not post information you do not want publicly available. FreedomPath may moderate public areas but cannot guarantee control over information once made public.

8. Marketing communications

You may unsubscribe from marketing email using the link in the message. If you consent to marketing text messages, message frequency may vary and message and data rates may apply. Reply STOP to opt out and HELP for help, or use another method stated in the message. Consent to marketing texts is not a condition of purchase unless expressly and lawfully stated. We may continue to send nonpromotional service, transaction, safety, or legal communications.

9. Automated decision-making, profiling, and artificial intelligence

We may use automated tools or artificial intelligence to support fraud prevention, personalization, customer service, marketing, credit education, product recommendations, or operational analysis. If we use automated processing to make or substantially facilitate a decision that produces legal or similarly significant effects, such as a decision concerning financial services, insurance, employment, housing, education, or access to essential services, we will provide notices, explanations, access, correction, opt-out, appeal, or human-review rights as required by applicable law. We do not use Personal Information to train a general-purpose model or permit a vendor to do so unless disclosed, contractually governed, and legally permitted.

10. Data retention

We retain each category of Personal Information only for as long as reasonably necessary and proportionate to fulfill the purpose for which it was collected, provide the Services, maintain security and continuity, comply with legal, tax, accounting, licensing, consumer-reporting, insurance, and contractual obligations, resolve disputes, enforce agreements, and establish or defend claims. We consider the amount, nature, and sensitivity of the information; risk of harm; applicable limitation periods; legal requirements; and whether the purpose can be achieved by other means. When retention expires, we delete, deidentify, or securely isolate information unless continued retention is required or permitted by law.

11. Security

We maintain administrative, technical, and physical safeguards designed to protect Personal Information, taking account of the nature and sensitivity of the information and the risks of processing. Measures may include access controls, encryption where appropriate, authentication, monitoring, vendor oversight, testing, employee training, incident response, and secure disposal. No system is completely secure, and we cannot guarantee absolute security. Please use a unique password and notify us promptly at support@freedompath.com if you suspect unauthorized account activity.

12. Your choices and privacy rights

Depending on where you live and subject to exceptions, you may have rights to:

• Confirm whether we process your Personal Information and access categories or specific pieces of it.
• Correct inaccurate Personal Information.
• Delete Personal Information.
• Obtain a portable copy of Personal Information you provided or otherwise covered by law.
• Know the categories of sources, purposes, and recipients and the categories sold, shared, or disclosed.
• Opt out of sale, sharing, targeted advertising, or qualifying profiling.
• Limit certain uses and disclosures of Sensitive Personal Information.
• Withdraw consent where processing depends on consent.
• Appeal our denial of a request.
• Receive equal service and not be unlawfully discriminated or retaliated against for exercising a right.

Submitting a request

Submit a request by emailing support@freedompath.com with "Privacy Request" in the subject line, or by calling (800) 960-7864. If a toll-free number or another method is legally required, these channels are designated for that purpose. To opt out of sale/sharing or targeted advertising, use an applicable opt-out preference signal.

We will acknowledge and respond within the time required by applicable law. We may ask for information reasonably necessary to verify your identity and authority, considering the sensitivity of the request. We will not request a full Social Security number, complete payment-card number, account password, or more verification data than reasonably necessary. We use verification information only for verification, fraud prevention, security, and legal compliance.

An authorized agent may submit a request where permitted. We may require proof of authorization and may ask you to verify your identity or confirm the authorization directly. Parents or guardians may exercise rights for a child as permitted by law.

If we deny a request, our response will explain the basis and, where applicable, how to appeal. Submit an appeal through support@freedompath.com. If an appeal is denied, you may contact the state regulator identified in our response.

13. California privacy notice

This section applies to California residents when the California Consumer Privacy Act, as amended ("CCPA"), applies to FreedomPath's processing. Terms defined in the CCPA have the same meanings here.

Notice at collection and disclosures

Sections 2 through 6 describe the categories of Personal Information and Sensitive Personal Information we collect, sources, purposes, and categories of recipients. Section 10 describes retention. We do not collect additional categories or use information for materially different, unrelated, or incompatible purposes without providing notice as required.

California rights

California residents may request to know/access, delete, or correct Personal Information; opt out of sale or sharing; limit qualifying uses or disclosures of Sensitive Personal Information; and receive nondiscriminatory treatment. You may exercise these rights as described in Section 12. We honor Global Privacy Control where required.

If we sell or share Personal Information, we will provide a clear "Do Not Sell or Share My Personal Information" or combined "Your Privacy Choices" link and will not require account creation or identity verification beyond what is permitted for an opt-out. We will not sell or share Personal Information of a consumer we know is under 16 without the affirmative authorization required by law.

Financial incentives

We do not offer a financial incentive or price/service difference related to the collection, sale, or retention of Personal Information. Ordinary discounts tied to a transaction should not be described as privacy incentives without legal review.

California "Shine the Light"

California Civil Code section 1798.83 may permit certain residents to request information concerning disclosures of specified personal information to third parties for their own direct-marketing purposes. Submit such a request using the contact information in Section 20 and include "California Shine the Light" in the subject line.

14. Additional U.S. state privacy rights

Residents of states with applicable comprehensive privacy laws may have the rights described in Section 12, including rights concerning targeted advertising, sale, profiling, Sensitive Personal Information, and appeals. We process requests under the law applicable to the requester and will provide state-specific information when required. Nevada residents may submit a verified request to opt out of covered sales under Nevada law using the methods in Section 12, even if our activities are not considered a sale under that law.

15. Financial, credit, identity, and insurance information

Certain information or activities may be governed by specialized laws, including the Gramm-Leach-Bliley Act, Regulation P, the Fair Credit Reporting Act, insurance privacy laws, identity-theft rules, and state financial-privacy laws. Where required, we provide a separate privacy notice, consumer-report disclosures, adverse-action or risk-based-pricing notices, insurance notices, or other product-specific disclosures. Those notices govern the covered information and activity. We obtain, use, disclose, furnish, and dispose of consumer-report information only as legally permitted. Nothing in this Policy authorizes use of consumer-report information for an impermissible purpose.

16. Children and teenagers

The Services are intended for adults and are not directed to children under 13. Persons under 18 may not enroll as Independent Brokers or members or purchase products or services through the Services. We do not knowingly collect Personal Information online from a child under 13 without verifiable parental consent when required. If you believe a child provided Personal Information contrary to this Policy, contact us using Section 20 so we can investigate and take appropriate action.

We do not sell or share Personal Information of consumers we know are under 16 without legally required opt-in authorization. If we materially change a Service so it is directed to children, or gain knowledge triggering children's-privacy duties, we will provide the required child-specific notice, obtain parental consent, limit collection and retention, and provide parental rights before continuing covered processing.

17. International users

The Services are operated from the United States, and Personal Information may be processed in the United States and other countries where we or our providers operate. Privacy laws in those locations may differ from those in your country.

18. Third-party services

The Services may link to or integrate with third-party websites, applications, social networks, or products. A third party may independently collect Personal Information when you interact with its service. Review that party's privacy notice. Our selection or integration of a provider remains subject to our legal and contractual responsibilities; this section is not a waiver or disclaimer of nonwaivable duties.

19. Contact us

FreedomPath
2835 Zelda Road Ste. 2 Montgomery, AL 36106
Email: support@freedompath.com
Telephone: (800) 960-7864

If you require this Policy in an alternative format, contact us using the information above.

20. Changes to this Policy

We may update this Policy to reflect changes in our practices, Services, or legal obligations. We will post the updated Policy and revise the "Last updated" date. If a change is material, we will provide additional notice appropriate to the circumstances, such as a prominent website or in-app notice, email, or renewed consent where required. We will not apply a materially different use retroactively without notice or consent when applicable law requires it.

21. Governing provisions

This Policy is a notice describing our privacy practices and is not intended to create contractual rights beyond those provided by applicable law. Nothing in this Policy limits or waives any nonwaivable privacy right or remedy. Any dispute-resolution provision in an applicable Terms of Use or other agreement applies only to the extent lawful and enforceable and does not prevent a consumer from submitting a complaint to a regulator or exercising a statutory privacy right.