Last Updated: 21 November 2025

This Privacy Policy (“Privacy Policy”) applies to all websites, web applications, mobile applications, and other online properties that link to or display this Privacy Policy (each, a “Platform”), and that are operated by Wing Financial, Inc. (“Wing,” “we,” or “our”). This Privacy Policy explains how we collect, use, disclose, store, and process personal information when you access or use any Platform, and when you engage with any investment advisory or financial planning services that Wing provides, in whole or in part, through the Platforms (collectively, the “Services”). It also applies to information you provide to us outside of the Platforms when communicating with us about your use of the Services, such as through email or other direct interactions.

Please read this Privacy Policy carefully before accessing any Platform or using the Services. By accessing or using a Platform, creating an account, or otherwise using the Services, you acknowledge that you have read and understand this Privacy Policy and agree to its terms, along with our Terms of Use.

The Services are intended solely for natural persons who are at least 18 years old. If you are under 18, you are not permitted to use the Services.

Information You Provide Us. In the course of using the Services, you may provide us with various types of information, including personal and financial information necessary for us to open, maintain, and service your account, communicate with you, and comply with regulatory requirements. This information may be collected when you create an account, interact with the Platforms, or communicate with us directly. We collect Contact Information, which typically includes your name, email address, phone number, and any details you provide in messages or inquiries. We use this information to begin the account application process, communicate with you about the Services, respond to your questions, send permitted communications (including required notices and marketing messages, where applicable), and deliver a personalized experience through the Platforms. If you apply to open an account, you will be required to provide Account and Regulatory Information necessary for identity verification, suitability analysis, and compliance with federal and state securities laws. This may include your date of birth, Social Security Number or other government-issued identification numbers, nationality and country of birth, employment and occupational details, educational background, marital status, passport numbers, tax identification numbers, and other information needed to verify your identity. You may also provide financial information such as bank account details, income, assets, liabilities, creditworthiness data (where permitted), account balances, and information relating to your investment objectives, risk tolerance, and financial profile. You will also be required to establish a username and password to access your account. To open and maintain an account with Wing, you must enter into an Advisory Account Agreement and any additional disclosures governing your advisory relationship and your use of the Platforms and Services.

Information We Collect Automatically. When you access or use the Services, we automatically collect certain technical and usage information about your interactions with the Platforms. This may include details about your computer or mobile device, your browser type, operating system, Internet Service Provider, IP address, device identifiers, the website or application that referred you to us, the pages or screens you view and the order in which you view them, the date and length of your visits, clickstream data, and other statistical information relating to your use of the Services. We may also develop aggregated demographic insights about users of the Services, such as general age ranges, geographic patterns, or similar non-identifying characteristics. We use cookies, web beacons, and other similar technologies to enhance and support your experience on the Platforms. These technologies help us recognize your device, maintain session integrity, store your preferences, understand how you navigate the Services, and measure the performance of our content and features. Although cookies and web beacons do not inherently contain personal information, they may be linked to personal information you provide, enabling us to tailor your experience, improve the Services, and support security and fraud-prevention efforts. We may also allow limited third parties to place cookies or similar technologies on the Platforms to help us analyze usage, measure engagement, understand user demographics, or deliver relevant content or marketing where permitted by law. These third parties may collect information about your online activities over time and across different websites or applications. Most browsers include tools to block or delete cookies. You may use these controls at any time; however, disabling cookies may impair certain features or limit functionality within the Services. With your consent, or as otherwise permitted by applicable law, we may send transactional or marketing SMS text messages to your mobile phone. These messages may be triggered by your activity on the Platforms, such as account alerts, security verifications, product updates, or support-related notifications. If you opt to receive SMS messages, we collect and store the mobile number you provide, as well as information associated with message delivery and interaction, such as when you open or read a message. Standard messaging and data rates may apply depending on your mobile carrier. You may opt out of SMS messages at any time by replying “STOP” to any Wing text message or by adjusting your communication preferences within the Platforms. Your consent to receive SMS messages is not required to open or maintain a Wing account; however, opting out may limit access to certain features or timely notifications.

How We Use and Share Your Information. We use personal and financial information to operate, deliver, and improve the Services, meet our regulatory obligations, and support the secure and efficient functioning of your account. This includes using your information to onboard you as a member; verify your identity; complete credit, AML, KYC, or other compliance checks; process transactions; service and maintain your account; and provide discretionary or non-discretionary advisory services. We also use your information to communicate with you about your account, respond to your questions, deliver updates about the Services, and provide information about new features or product enhancements. We use information to understand how the Services are used, monitor performance, maintain security, enhance functionality, and support ongoing analytics, troubleshooting, and product planning. We may use your information to develop insights about trends and user behavior, improve the design and operation of the Platforms, and support permitted marketing activities where required consents have been obtained. We also use information to detect, investigate, and prevent fraud, malicious activity, system abuse, and violations of our terms, as well as to protect the rights, security, and integrity of Wing, our users, and our systems. We may share your information with third-party contractors, service providers, and other entities that assist us in delivering the Services or supporting our business operations. These may include administrators; broker-dealers; custodians; Model Providers, Advisers, Sub-Advisers and Partners; payment processors; IT, hosting, and cloud service providers; security and fraud-prevention vendors; analytics providers; and other technology, operational, and professional service providers. We may also share information with our auditors, attorneys, and other advisers in connection with receiving their professional services, subject to standard confidentiality obligations. We may disclose aggregated, de-identified, or anonymized information to business partners, prospective partners, and other third parties for lawful purposes, including describing the Services, supporting product development, or conducting analytics. We may also share information with our subsidiaries, affiliates, and other companies under common ownership or control, consistent with this Privacy Policy and applicable law. We will disclose personal information as necessary to satisfy our legal and regulatory responsibilities. This includes responding to subpoenas, court orders, lawful government requests, regulatory examinations, or when we believe in good faith that disclosure is necessary to protect our rights, protect the safety of you or others, investigate fraud, or comply with applicable laws. In the event of a corporate transaction, such as a merger, acquisition, investment, reorganization, financing, or sale of some or all of our business, your information may be transferred as part of the transaction, subject to this Privacy Policy. We take reasonable steps, including through contractual obligations, to require any third party that receives personal information from us to (a) use such information only as permitted by this Privacy Policy and applicable law; (b) maintain the confidentiality and security of such information; and (c) limit its use to purposes related to providing services to Wing or supporting the Services.

How Long We Retain Your Information. We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. As a regulated investment adviser, Wing must retain certain records in accordance with the Investment Advisers Act of 1940 and other applicable laws, which may require retention beyond the closure of your account.

Do We Support “Do Not Track” Signals? At this time, the Services do not respond to “Do Not Track” browser signals. You may learn more about Do Not Track at donottrack.us. Where required by applicable law, Wing will recognize and honor browser-based opt-out signals such as Global Privacy Control (GPC) for processing activities that qualify as “sales,” “sharing,” or “targeted advertising” under state privacy laws. If Wing engages in such processing in the future, a GPC signal transmitted from your browser or device will be treated as a valid request to opt out of such activities. You may also submit an opt-out request directly to Wing at any time by contacting support@wing.app. We will act on valid opt-out requests within the timeframe required by law.

California “Shine-the-Light” Disclosure. We do not share your personal information with unaffiliated third parties for their own direct marketing purposes.

How We Protect Your Information. We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, loss, or misuse. This includes encryption of sensitive information during transmission and secure storage protocols once information is received. Although we work diligently to protect your data, no method of electronic storage or transmission is entirely secure. Our Services operate on software, hardware, and networks that may, from time to time, experience security vulnerabilities or events beyond our control. Accordingly, we cannot guarantee that your information will remain absolutely secure, and you transmit information at your own risk. You also play an important role in safeguarding your information. You should not share your username or password with others, and you are responsible for maintaining the confidentiality of your account credentials. If we receive instructions that appear to be associated with your account, we will assume that you have authorized the activity.

Third-Party Websites and Integrated Services. The Services may contain links to websites or services operated by third parties. These websites are governed by their own privacy policies, not this Privacy Policy. We are not responsible for the privacy practices of third-party sites, and we encourage you to review their policies before submitting any information. Certain features of the Services may rely on third-party integrations, including advertising networks, analytics providers, or service partners that support data collection, reporting, measurement, or the delivery of relevant marketing content. These third parties are prohibited from collecting personal information through our Platforms except as permitted under this Privacy Policy or applicable law. However, Wing is not responsible for the privacy practices of such third parties.

How You Can Update or Manage Your Information. You may request to update, correct, or delete your personal information at any time by contacting us at support@wing.app. You may also choose to opt out of promotional communications by following the instructions included in those communications. Opting out will not affect transactional or account-related communications, which are necessary to operate your account and the Services.

Data Minimization and Retention. Wing practices data minimization and collects only the personal information necessary to provide the Services, fulfill our legal and regulatory obligations, maintain the security and integrity of our systems, or accomplish the purposes described in this Privacy Policy. We retain personal information only for as long as necessary to meet these purposes or as required by law, including the recordkeeping obligations applicable to registered investment advisers. When personal information is no longer needed, we will delete, anonymize, or securely store it until deletion is possible.

Children’s Privacy. The Services are not directed to children under 13, and we do not knowingly collect personal information from anyone under 13 years of age. If you are under 13, you may not use the Services. If you become aware that a child under 13 has provided us with personal information, please contact us, and we will take reasonable steps to delete the information from our systems.

Changes to This Privacy Policy. We may update or modify this Privacy Policy periodically. Changes will apply prospectively, and the “Last Updated” date at the top of this Privacy Policy reflects the most recent revision. We encourage you to review this Privacy Policy regularly. Your continued use of the Services after any update constitutes your acceptance of the revised Privacy Policy.

International Transfers of Personal Information. The Services are operated in the United States, and personal information may be processed and stored in the United States or in other jurisdictions where Wing or its service providers maintain operations. These jurisdictions may have data-protection laws that differ from those in your home country. Where legally required, Wing implements appropriate safeguards to protect personal information transferred across borders, including contractual protections and other mechanisms permitted under applicable law. By using the Services, you understand that your information may be transferred to and processed in the United States.

Nevada Residents. We do not sell personal information as defined under Nevada law. However, Nevada residents may request to opt out of future sales of their personal information by emailing support@wing.app with the subject line “Nevada Do Not Sell Request” and including the name and email address associated with their Wing account.

Additional U.S. State Privacy Rights. Certain U.S. state laws provide residents with specific rights regarding their personal information, which may include the right to access, correct, delete, or obtain a portable copy of personal information we maintain about you, as well as the right to opt out of certain processing activities. These rights may vary based on your state of residence. Wing does not sell personal information, but where applicable law grants additional rights, you may exercise them by contacting support@wing.app and we will respond within the legally required timeframe. We will not discriminate against you for exercising any privacy rights afforded to you under state law.

Contact Us. If you have questions or comments about this Privacy Policy or our data-handling practices, you may contact us at support@wing.app.