INSPIRA FINANCIAL PRIVACY POLICY

We at Inspira Financial Trust, LLC, including its affiliates Inspira Financial Health, Inc. and Inspira Financial Health Holdings, Inc. (collectively, “Inspira Financial”) respect your concerns about privacy. This Privacy Policy (the “Privacy Policy”) explains what personal information we collect when you interact with us via phone or online, including via our websites, platforms, portals, applications or similar (collectively, “Online Services”), how we collect, use, and protect it, and why, in certain cases, we may share it with select third parties. This Privacy Policy also explains your rights in relation to your personal information, including your sharing and use choices.

What types of personal information are collected?

The types of personal information we may collect and use will depend on how you interact with us. This information can include:

• Personal identifiers, such as Social Security number, driver’s license, date of birth, voiceprints, voice biometrics, face geometry and/or face biometrics and other personal information necessary to verify your identity, and access authorization information, such as username, passcode and security questions and answers
• Information you provide on applications or other forms in order to receive our products and services, such as banking information and demographic information
• Account-related and transaction data, such as account number, balance, transactions, and information about beneficiaries
• Recordings and transcripts of customer service calls and communications
• Recordings of voiceprints and voice biometrics you provide for account services
• Contact information you provide, such as name, email address, and telephone number(s) in order to receive transactional, product and marketing information from us
• Device data, such as device type, web browser type and version, operating system type and version, internet protocol address, mobile network information, general location (e.g., city, state, or country), cookie IDs, device IDs, mobile advertising IDs, and likely connections among different browsers and devices that you use
• Online/mobile activity data, such as login data, search history, language, statistical identifiers, and information about how you use and interact with our Online Services or advertising
• Marketing data, such as marketing preferences, information about products or services we think you might like, and inferences based on your interactions with us or information we learn about you
• Communications data, such as your communication preferences and details or the content of your communications with us
• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

If you disclose any information relating to other people to us when you visit or use our Online Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

We retain personal information for a period of time as required by laws and regulations and the necessary business purpose. We securely delete personal information as soon as legally permitted and in accordance with our internal retention policy.

How does Inspira Financial collect my personal information?

We collect information in a variety of contexts when you use our Online Services. For example, we may collect information:

• Directly from you – We collect information directly from you when you submit information to us, such as when you open an account or withdraw or deposit money, pay fees or conduct transactions through your account, use your credit or debit card or provide banking information, register for a product or service or request information about a product or service, submit or upload information or documents, or input in any free-text boxes or forms through our Online Services, or complete a survey, sweepstakes or other promotion.
• Automatically when you use our Online Services – We, and others on our behalf, may collect the information described in this policy, such as device, online/mobile, or communications data, automatically when you interact with us online. This includes using cookies to collect information such as site visitorship and device data, user navigation and user behavior.
• From our service providers – We may also collect information from third-party service providers who assist us in providing our services to you. These service providers may include your health insurance company or other third parties we contract with to provide our services. We may receive information from these service providers in various ways.

We may also collect information in other contexts, such as from our phone calls, chats and emails with you, or from third-party data sources for fraud prevention, identity verification, or marketing purposes.

How can personal information be used?

We use personal information that is collected about you for many purposes, such as:

• Providing, maintaining and servicing your accounts and delivering products and services, by verifying your identity, processing applications for products or services such as to open an account, and processing transactions
• Determining your financial interests and needs in order to recommend relevant products and services
• Authenticating your identity, preventing fraud, and keeping your information and financial transactions secure
• Advertising and marketing
• Optimizing your online and mobile experience and improving our products and services
• Performing analytics using aggregated and de-identified information regarding your use of our Online Services
• Complying with and enforcing applicable legal requirements, industry standards, contractual obligations and our policies
• Managing workforce activities and personnel generally, including for recruitment, performance management, career development, payments administration, employee training, leaves and promotions

How does Inspira Financial protect my personal information?

To protect your personal information from unauthorized access, use, or disclosure, we maintain technical and organizational security measures that comply with federal and state laws. These measures include computer safeguards, secured files and restricted access to buildings, as well as training employees to comply with privacy standards and policies which are designed to protect personal information.

When can information be shared?

We do not sell for money or otherwise share personal information about you, except as described in this Privacy Policy.  We share personal information with third parties who perform services on our behalf.  These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share the personal information we obtain with our affiliates and joint marketing partners.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) in response to requests by government agencies, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

If applicable to you, refer to the U.S. Consumer Privacy Notices for Inspira Financial Trust, LLC (https://inspirafinancial.com/privacy-policy/privacy/us-financial-consumer-privacy-notice) and Inspira Financial Health, Inc. (https://inspirafinancial.com/privacy-policy/privacy/us-health-consumer-privacy-notice).

This Privacy Policy was last updated on January 8, 2024 and may be amended from time to time.