Distl Finance Privacy Policy

Last updated: September 2024

This Privacy Policy explains how we collect, use and disclose personal information and other information about you in connection with your use of distl.ai (this “Website”) and any Distl (as defined below) applications, products and services (collectively, “Services”) that may be available to you on this Website or that otherwise link to this Privacy Policy. Our Website and Services are not intended to be used by persons that are not located in the United States.

This Privacy Policy applies only to this Website and the Services. If you use other websites and/or other products or services offered by Distl or any of our affiliated entities, please review the applicable privacy policy (or policies) associated with those websites, products and services.

Who we are
DistlSM is a standalone brand representing a subset of services provided by Catchlight Insights LLC (“Distl”). In this Privacy Policy, Distl and its affiliates are referred to as "Affiliated Companies”.

How and why we obtain and use personal information
As used in this Privacy Policy, “personal information” means information about an individual that is collected or maintained for business purposes and by which the individual can be identiﬁed. Please note that information by which an individual cannot be identiﬁed (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this Privacy Policy.

Distl and its service providers obtain and use personal information about you as described below. For example, personal information about you is used to provide the Website and the Services to you; respond to inquiries from you; develop, oﬀer, and deliver products and services; operate and manage our business; and fulﬁll legal and regulatory requirements.

Distl collects public and non-public personal information from users of our Website and Services from various sources. Some examples include:

• You, from your interactions with our Website and/or Services, including information you enter into the Website (for example, name, email address and phone number entered on forms on this Website);
• You, regarding your preferences (for example, managing your communication preferences or for any customizable features of this Website or any of the Services);
• You, from your interactions with emails sent to you in connection with the Services (for example, whether you clicked on a link embedded in an email);
• The financial advisors we provide services to;
• Through the software (e.g., web browsers) and devices that you use to access this Website or any of the Services or other electronic communications from us (for example, device type, browser type, internet protocol address, pages visited on this Website, and time spent on this Website or using the Services;
• Affiliated Companies;
• Third parties that perform services for us or on our behalf (for example, to verify your identity and to better understand your product and service needs);
• Other third-party sources, including government sources, data brokers and social networks, and publicly available sources (for example, key household details, possible household life events, and interests);
• Other sources with your consent or directed by you.

When you use or interact with us via our Website or Services, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our Website and Services. Please see the section titled “Cookies and similar technologies” below for a description of the technologies used to automatically collect this information from you. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience.

We may use the personal information we or our service providers collect:

• To facilitate an introduction to financial professionals when you indicate your interest in connecting or corresponding with a financial professional via our Website or Services;
• To provide information about you to financial professionals to help them prioritize their outreach and understand your background and interests, as further described in the Catchlight Privacy Policy;
• To enable integrations with third party products and platforms that you elect to use;
• To allow you to use this Website and the Services, and to facilitate and personalize your interactions and experiences with us;
• To respond to inquiries from you and fulfill requests from you;
• To market and communicate to you;
• To display advertisements to you for our Website and/or Services;
• To obtain your feedback to improve your experience with this Website and Services, including through optional surveys;
• To provide and improve this Website and the Services, and develop, offer and deliver other products and services;
• For our and other Affiliated Companies’ respective business purposes, such as reporting, planning and analytical purposes, and training and quality control purposes;
• To detect and prevent fraudulent, malicious or illegal activity, for risk control and mitigation purposes, and to fulfill legal, judicial, contractual and regulatory requirements; and
• In connection with corporate business transactions, such as a merger, joint venture, corporate reorganization or sale of a business.

How we protect information about you
We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology.

How we share information about you with our affiliates
We may share personal information with various other Affiliated Companies that are providing services to us, such as administrative, business and data processing services. In addition, we may share personal information about you with other Affiliated Companies for use in their businesses, including developing, marketing, offering and delivering their products and services.

How we share information about you with third parties
We may share certain information we collect about you with the following entities:

• Our financial advisor clients;
• Unaffiliated service providers and other third parties with which we or other Affiliated Companies have a business relationship;
• Government agencies, other regulatory bodies and law enforcement;
• Other organizations conducting research or performing academic or similar activities;
• Financial professionals, if you chose to use certain features or functionality of this Website or Services or indicate your interest in connecting with such individual or firm via our Website or Services (e.g., when you submit a question or indicate interest to connect with a financial professional);
• Other third parties, as directed by you;
• Other organizations as permitted or required by law (for example, for fraud prevention or to respond to a subpoena); and
• In connection with corporate business transactions, such as a merger or sale of a business.

Our unaffiliated service providers are obligated to keep the personal information we share with them confidential.

In addition, if you choose to use or indicate your interest in using a product, service or other offering that is offered by a third party and made available through Distl, we may share personal information with that third party in connection with your use of or interest in that product, service or offering.

Cookies and similar technologies
Distl and our third-party service providers may use cookies and similar technologies (“cookies”) to support the operation of and maintain our Website and Services. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our Website, including date and time of visits, pages viewed, links clicked, amount of time spent using our Website, or general information about the device used to access our Website. Distl cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Both Distl and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices oﬀer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our Website, as some features and services on our Website or Services may not work properly. For example, you may not be able to access our Website and/or Services, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.

We may also use cookies and similar technologies in emails sent in connection with the Services. Depending upon the email client/service that you use, you may have the option to prevent the automatic downloading of images which would suppress these cookies and similar technologies.

We may collect analytics data or use third-party analytics tools such as Google Analytics or Meta to, among other things, help us measure traffic and usage trends for our Website, to improve the effectiveness of our online advertising, and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy. You can also view Google’s currently available opt-out options.

Advertising on Distl
Distl advertises on its own Website, and when we do, we may use information about your relationship with us to tailor advertisements and communications about Distl and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Distl products and services may be of interest to you. These service providers may use cookies and other technologies to collect for us information about your activity on the Distl Website. We and our service providers use such information to analyze the effectiveness of our advertising and the usage of our Websites and Services. For example, we may analyze the browsing patterns while visiting the Website and responses to advertisements and promotions shown on our Website. Such service providers may only collect and use such information for purposes speciﬁed by Distl and not for their own purposes.

Advertising on Non-Distl Digital Offerings
Distl may also advertise our Website and Services on websites not aﬃliated with Distl and when we do so we may contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Distl and these third-party online advertising companies, including Meta, may use the data collected, along with other information we have about you and your relationship with Distl, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on this Website and on non-Distl websites. These advertisements are known as "interest-based advertisements".

You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by Distl, by clicking on the AdChoices icon and following the opt-out instructions.

If you generally want to “opt out” of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in a self-regulatory programs like the Digital Advertising Alliance DAA program or the Network Advertising Initiative (NAI), please follow the instructions at WebChoices: Digital Advertising Alliance's Consumer Choice Tool for Web US (aboutads.info) and NAI Consumer Opt Out (networkadvertising.org) to place an “opt-out” cookie on your device indicating that you do not want to receive interest-based advertisements. If you want to “opt out” of receiving online interest-based advertisements on mobile devices, please follow the instructions at YourAdChoices.com | AppChoices and Mobile Opt Out - NAI: Network Advertising Initiative (thenai.org).

Connecting with Distl on social media platforms
Distl provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Your interactions with financial professionals.
When you interact directly with a financial professional and provide or otherwise make available information to them, please keep in mind that the financial professional’s collection and use of any such information is governed exclusively by the financial professional’s agreements, privacy policies, disclosures and statements and not by this Privacy Policy. You should consider, among other things, the nature of the information that you provide or otherwise make available to the financial professional, the purposes for which the financial professional will use your information, and the commitments the financial professional makes regarding its protection of the privacy and security of your information. Please read and review carefully each financial professional’s agreements, privacy policies, disclosures and statements to understand how your information is accessed, used, shared, handled, retained and protected by the financial professional and their firm.

Third Party websites, online service, and content
Our Website may contain links to third party websites and online services (for example, social media platforms) and may include embedded content that is hosted by third parties. This Privacy Policy does not address the privacy, security, cookie policy and settings, or other practices of the third parties that provide such websites, online services, or content, and we are not responsible for the privacy practices or the content of these other websites, online services, or content providers. If you use a link to another website or online service or view third party content (for example, an embedded video), please consult the privacy policy for that website/or online service for additional information on their privacy practices and advertising opt-out instructions.

Children's privacy
Distl’s Website and Services are not directed to individuals under the age of thirteen (13). Distl does not intentionally collect information on this Website from those we know are under 13, and we request that these individuals do not provide personal information through our Website. If we do provide a website that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.

Updates
We may change this Privacy Policy at any time, and without notice to you, by posting an updated Privacy Policy on this Website or otherwise providing you with a copy of the updated Privacy Policy. When we make changes to this Privacy Policy, we will change the “Last Updated” date specified at the beginning of this Privacy Policy. All changes shall be effective from the date the updated Privacy Policy is published, unless otherwise specifically stated in the updated Privacy Policy. We encourage you to review this Privacy Policy on a regular basis so that you will be aware of any changes to it.

Additional information
If you have questions or concerns about this Privacy Policy, please contact us at hello@distl.ai

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