ARCHITECT FINANCIAL TECHNOLOGIES INC.

PRIVACY POLICY

Last Updated: October 7, 2026

This Privacy Policy describes how Architect Financial Technologies Inc., and its affiliates and subsidiaries (collectively, “Architect,” “we,” or “us”) will collect and use personal information and the circumstances under which we may share this information. This Privacy Policy applies to all visitors to Architect’s website located at https://www.architect.co (the “Website”), those accessing Architect’s products and services (collectively, our “Services”), or when you otherwise interact with us directly, such as through our customer support channels or on social media. We may provide different or additional notices of our privacy practices with respect to certain products or services, in which case such notices will supplement but not supersede this Privacy Policy.

CONTENTS

Collection and Use of Information

Disclosure of Information

Transfer of Information to the United States and Other Countries

Retention of Information

Cookies and Similar Technologies

Security

Your Rights

California “Shine The Light” Law

Your Choices

Updates to this Privacy Policy

Contact Us

COLLECTION AND USE OF INFORMATION

We may collect the following information about you during your interaction with the Website and/or Services:

Category of Information Purpose/Lawful basis Type of Information Collected Method of Collection
Onboarding, Know Your Client and Account Creation Information Legal obligation under financial services laws and regulations. Name, email address, phone number, business information such as company name and job title, social security number, birth date, photo ID, country of residence and nationality, national and governmental identification information, and financial, banking or other payment related details. Directly from you or your employerFrom third parties, e.g. identity verification services, fraud prevention agencies, websites, and other publicly accessible information.
Contact information Our legitimate interests in:Sending you technical notices, security alerts, support messages and other transactional or relationship messagesCommunicating with you about products, services and events offered by Architect and others and provide news and information that we think will interest you (see the “Your Choices” section below for information on how to opt out of these communications at any time)Sending you information related to your use of our Services, including but not limited to confirmations, receipts, invoices, and customer surveysTo comply with our legal, regulatory and financial obligations. Name, email address, postal address, phone number. Directly from you or your employer
Usage Information Our legitimate interests in:Providing, maintaining, improving and developing new products and services, including debugging and repairing errors in our ServicesProcessing transactionsMonitoring and analyzing trends, usage and activities in connection with our products and servicesDetecting, investigating and helping prevent security incidents and other malicious, deceptive, fraudulent or illegal activity and help protect the rights of Architect and othersTo comply with our legal, regulatory and financial obligations Information related to your use of and interactions with our Services, such as your name, account information, interactions with our Website, and trade activity.Device information (e.g. data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version)Cookies and beacons Directly from you or your employerAutomatically
Communication Information Our legitimate interests in:Sending you technical notices, security alerts, support messages and other transactional or relationship messagesCommunicating with you about products, services and events offered by Architect and others and provide news and information that we think will interest you (see the “Your Choices” section below for information on how to opt out of these communications at any time)Sending you information related to your use of our Services, including but not limited to confirmations, receipts, invoices, and customer surveys Any information included in communications between you and Architect Directly from you
Employment application Information Our legitimate interests in assessing and recruiting prospective employees Name, address, email and phone numberEducation and employment historyAny other information provided or recorded with respect to your application Directly from youFrom third parties, e.g. LinkedIn, your referencesDerived by us
Social Media Information Our legitimate interests in communicating with you about products, services, and events offered by Architect and others. Any information submitted through social media or other channelsIP address, which page you are visiting on our Services Directly from youFrom third parties, e.g. social media platformsDerived by us

Please review our Privacy Notice located at: https://www.architect.co/legal for a description of our processing and disclosure activities regarding the non-public personal information we collect from and about you.

Our Website and Services are intended for individuals who are at least 18 years old. We do not knowingly collect personal information from children, and we do not sell or share the personal information of anyone under 18.

If you make a purchase, we work with third-party payment processors to collect and process your payment information. These include Plaid Inc. and Stripe, LLC. We do not store full payment card numbers.

DISCLOSURE OF INFORMATION

We may disclose personal information in the following circumstances or as otherwise described in this policy:

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Architect is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing the latest EU Standard Contractual Clauses or the UK Addendum issued by the UK Information Commissioner’s Office (as applicable). For customer of Architect’s Liquid Inference, inference providers may process requests in the countries disclosed in their listings, and our Data Processing Agreement includes additional transfer terms for personal information our customers submit.

RETENTION OF INFORMATION

We will only retain personal data for as long as we have a legitimate basis for doing so, including for the purposes of satisfying any legal, regulatory, commercial, accounting, or reporting requirements.

To decide on the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will generally retain information relating to business relationships for as long as there is an ongoing relationship and an appropriate period following the end of that relationship. Once we have no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies on our websites to keep them secure and working, to remember your settings, and, with your consent where required, to understand how they are used through Google Analytics and PostHog. On the Liquid Inference website and application, PostHog records which pages and features are used, and, with your consent, recordings of your sessions that hide what you type. We do not use targeting or advertising cookies. For details and your choices, see our Cookie Notice.

SECURITY

We use technical and organizational measures designed to protect personal information, such as access controls and encryption in transit. No system is completely secure, and we cannot guarantee the security of information you send to us.

YOUR RIGHTS

If you are located in the United Kingdom, the European Economic Area, certain US states, or any other location with equivalent data protection regimes, you may have certain rights under applicable data protection laws in relation to your personal data.

If you want to exercise any of these rights, please contact us using the contact information below. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Additional U.S. state rights. Depending on where you live, you may also have the right to appeal our decision on your request, to opt out of the sale or sharing of personal information or of targeted advertising, and not to be discriminated against for exercising your rights. You may use an authorized agent where the law permits. We do not sell personal information or share it for cross-context behavioral advertising. Where we process personal information on behalf of a business customer, such as personal information in Liquid Inference Prompts, we may refer your request to that customer.

We note that where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to act on the request.

CALIFORNIA “SHINE THE LIGHT” LAW

Where businesses disclose personal information of California residents to third parties for their direct marketing purposes, California law requires them to either provide a mechanism to obtain more information about these disclosures from the previous calendar year, or provide a mechanism for California residents to opt out of these disclosures. We do not disclose your personal information to third parties for their direct marketing purposes, so we are not required to provide an opt-out.

YOUR CHOICES

Account Information

You may update, correct certain account information, or deactivate your account at any time by contacting us at [email protected]*.* Please note that we may retain certain information as required by law, our regulatory requirements, or for our legitimate business purposes.

Communications Preferences

You may opt out of receiving promotional emails from Architect by following the instructions in those communications or by emailing us at [email protected]. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our privacy practices. We will post the updated version with a new “Last Updated” date and, where required by law, give you additional notice of material changes. We encourage you to periodically review this page for the latest information on our privacy practices, and any use of our Website after any updates constitute your acknowledgement that you have read the updated Privacy Notice.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected] or by mail at the following address: Architect Financial Technologies Inc. 1 E Erie St, Suite 525-5211, Chicago, IL 60611.