Privacy Policy

Introduction

Magnitude Inc. ("Magnitude," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our financial services platform and mobile application.

Magnitude Inc. is the controller of your personal information. Magnitude Ultralight, our financial planning app, is offered in the United States, Brazil, Mexico and Spain. Magnitude Ultra and our banking, card and payment services are offered only in the United States. The section “Your Rights Outside the United States” below explains the rights you have under the laws of Brazil, Mexico and the European Union.

Magnitude is a financial technology company, not a bank. Magnitude has not yet launched banking services. When it does, banking services will be provided by one or more FDIC-insured partner banks, which we will identify before you open an account. Funds held at a partner bank will be eligible for FDIC insurance up to $250,000 per depositor, per insured bank, subject to applicable limits.

Information We Collect

Personal Information

We may collect the following types of personal information:

• Name, email address, and contact information
• Government-issued identification and Social Security Number (as required for banking services)
• Income and employment information, including pre-tax income, employer name, and tax form type
• Financial information necessary to provide our services
• Device information and usage data

Automatically Collected Information

We use Umami Analytics, a privacy-focused analytics service that does not use cookies or collect personal data. Umami collects anonymous usage statistics to help us improve our service.

Polls and surveys. When you answer a poll or survey, we store a random identifier in your browser's local storage. It is not a cookie, contains nothing about you, and is never shared. If you later join our waitlist from the same browser, we use it to connect those earlier answers to your email address, so we can understand what people told us before they signed up. You can clear it at any time by clearing your browser's site data. If you are in the European Economic Area, the United Kingdom or Switzerland, we do not store this identifier in your browser, so answers you give are not linked to a later sign-up.

How We Use Your Information

We use your information to:

• Provide, maintain, and improve our financial services
• Process transactions and manage your account
• Comply with legal and regulatory requirements
• Communicate with you about your account and our services
• Prevent fraud and enhance security
• Analyze usage patterns to improve user experience

Legal Bases for Processing

Where the law of your country requires a legal basis for using your personal information, including the EU General Data Protection Regulation (GDPR) and Brazil's General Data Protection Law (LGPD), we rely on:

• Providing the service you asked for - To create your account, build your plan and run the app
• Legitimate interests - To keep our services secure, prevent fraud, and understand how our services are used so we can improve them, where those interests are not overridden by your rights
• Consent - Where we ask for it, such as for marketing emails. You can withdraw consent at any time, without affecting anything we did before you withdrew it
• Legal obligations - To comply with laws that apply to us

Information Sharing

We share your information only in the following circumstances:

• With our partner banks - Once banking services launch, the FDIC-insured banks that will provide deposit accounts and other banking services
• Service Providers - Third-party services that help us operate, including Supabase (database), Resend (email communications), and Umami (analytics)
• Legal Requirements - When required by law, regulation, or legal process
• Business Transfers - In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties.

International Transfers

Magnitude is based in the United States, and our service providers store and process your information in the United States. If you live in Brazil, Mexico, Spain or elsewhere outside the United States, your information is transferred to the United States. Where the law of your country requires it, we protect these transfers with safeguards that law recognizes, such as standard contractual clauses.

Data Security

We implement industry-standard security measures to protect your personal information. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Once banking services launch, they will be subject to our partner banks' security standards and regulatory compliance requirements.

Your California Privacy Rights (CCPA)

If you are a California resident, you have the following rights:

• Right to Know - Request information about the personal data we collect, use, and share
• Right to Delete - Request deletion of your personal information
• Right to Opt-Out - We do not sell personal information, so no opt-out is necessary
• Right to Non-Discrimination - We will not discriminate against you for exercising your privacy rights

To exercise these rights, contact us at privacy@magnitude.money.

Your Rights Outside the United States

European Union, including Spain (GDPR). You have the right to access your personal information, to correct it, to have it erased, to restrict or object to how we use it, and to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time. You also have the right to lodge a complaint with a data protection authority, in Spain the Agencia Española de Protección de Datos (AEPD). Our representative in the European Union under Article 27 of the GDPR is Joshua Martens, based in Barcelona, Spain, reachable at privacy@magnitude.money.

Brazil (LGPD). You have the right to confirm whether we process your personal information and to access it, to correct incomplete or inaccurate information, to have unnecessary or excessive information anonymized, blocked or deleted, to data portability, to information about who we share it with, to withdraw consent, and to petition the Autoridade Nacional de Proteção de Dados (ANPD). Our Data Protection Officer (Encarregado) for Brazil is Frederico Murakawa, based in São Paulo, Brazil, reachable at privacy@magnitude.money.

Mexico. Under the Federal Law on the Protection of Personal Data Held by Private Parties, you have the right to access your personal information, to rectify it, to cancel it and to oppose its use (ARCO rights), and to revoke your consent. If you believe your rights have been violated, you may contact the Mexican data protection authority.

To exercise any of these rights, email privacy@magnitude.money. We will respond within the time required by the law that applies to you, and we may need to verify your identity first.

Data Retention

We retain your personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Banking and financial records may be retained for longer periods as required by law.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after changes become effective constitutes acceptance of the updated policy.

Contact Us

If you have questions about this Privacy Policy, please contact us:

• Email: privacy@magnitude.money
• Mail: Magnitude Inc., 1007 N Orange St, 4th Floor, Ste 1382, Wilmington, DE 19801, United States