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PRIVACY POLICY

Effective Date: February 13, 2025 Last Revised: February 5, 2026

This Privacy Policy describes the types of information gathered by Magnolia Financial Services, Inc. (“Magnolia”, “us” or “we”) in the process of providing https://magnolia.financial (the “Site”) and the data, services, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service.

By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, https://magnolia.financial/tos, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.

This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Territoriality

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

Who Collects Your Information On Our Service?

We do. We collect personally identifiable information (“PII”) from you on the Service, and we are responsible for protection of your information.

What Information Do We Collect?

  1. Personal Information. We collect certain PII from you when you sign-up for the Service, when you complete a survey, when you create or update an account, when you use the Service, when you request services, or otherwise when you submit such information. The types of PII we collect and save include:

    • Name, social security number, address, phone number, credit card number, username, email address, credit reports, and driver’s license number.
    • Technical information collected in our logs. Such information may include standard web log entries that contain your device identifiers, first-party session cookies, IP address, web beacons, page URL, and timestamp.

    You may provide us with information when you interact with us through email, read an email from us, messaging functions within the Service, or otherwise. We may retain such information in order to provide you with Services.

  2. Non-Personal Information. “Non-Personal Information” is information which doesn’t identify you and/or anonymous information about you, including but not limited to links and materials posted, transaction history, the type of device you used and its operating system, browser information, the pages accessed most frequently, how pages are used, when and how you use the Service, search terms entered, and similar Non-Personal Information.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools. Through collecting your IP address, we may be able to approximate your geographic location, however, unless and until this is information is paired with your PII, it cannot be used to identify you. If Non-Personal Information is paired to any of your PII, we will treat the Non-Personal Information as if it was PII too.

  1. Aggregate Information. We may also collect anonymous, non-identifying, and aggregate information, such as the date and time of any request, language preference, referring website, the pages you visit within our Site, the website you go to after visiting our Site, and the domain name of your Internet service provider.

  2. Financial Information. Although it may appear that we collect financial information from you on the Service, it is actually collected and processed through a third-party service provider (“Payment Processor”) to process payments for the Service. The Payment Processor may collect financial information such as banking information or credit card number, name, CVV code or date of expiration, from you on the Service. We do not hold your financial information.

Why Is My Information Being Collected?

We accept and gather information in an effort to provide the Service to you. We need to collect your PII so that we can respond to your requests for information or to be added to our email lists, to process your payment for the Service. We may also collect aggregate information, to help us better design the Service, and log information, for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.

How Do We Use the Information We Collect?

We use the PII you provide for the purposes for which you have submitted it including:

  • Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, conduct experiments, develop and improve the Service and other offerings, and perform research and analytics.

  • Anti-Money Laundering and Know Your Customer (KYC) Compliance. In order to comply with domestic and international industry standards, government rules and regulations, in particular the Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) rules and Counter-Terrorist Financing (CTF) regulations, we are required to collect and retain your PII.

  • Creating and Maintaining Your Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service, including those aspects that may be enabled or enhanced by artificial intelligence.

  • Paying for the Service. To the extent necessary, our payment information is collected by, and processed through, our Payment Processor.

  • Communicating With You About Our Services. We may use your PII to send you information about new services and other items that may be of interest to you.

  • Sending Administrative and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account information and your other PII; (b) process your transactions to purchase our Service; (c) provide you with information regarding the Service; (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (e) provide you with information on our other services and products, or promotions related to the Service or our other services and products.

  • Sharing Information. We may disclose your PII as described below.

  • Mailing You Something. From time to time, we may send you something relating to the Service via USPS, courier, or another service.

We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services. We may use any anonymous, aggregate information, of which your information may be a part of or the basis of, without restriction.

Do We Share Your PII?

We will not share your PII except: (a) for the purposes for which you provided it; (b) with your consent, such as other users of the Service; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to carry out internal operations or business activities.

We may also share aggregate information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer your PII to a third party, or an actual or potential successor-in-interest, in relation to, or in the event of, an actual or potential merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.

Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain personal information with individuals or with the public via your use of the Service. In this case, you will control such sharing via settings that we provide. Be aware that when you choose to share information you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Service.

How Can You Access And Control Your Information?

After becoming a user of the Service, you may revise or edit your information by sending an email to [email protected]. For instructions on how you can further access your PII that we have collected, or how to correct errors in such information, please send an e-mail to [email protected]. Upon your request, we will delete your personal information from our systems within 30 days, except where we are required by law to retain certain records. As a registered Money Services Business, we are required by federal law, including the Bank Secrecy Act (BSA) and its implementing regulations, to retain certain customer identification and transaction records for a minimum of five (5) years. If your deletion request cannot be fully honored due to legal retention requirements, we will inform you and restrict the use of any retained data to only what is necessary to comply with our legal obligations. Furthermore, you may opt out of the use of information by the Service to send you promotional emails by sending an email to [email protected] with "Opt-Out" in the subject line. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections, or removing your information.

How Do We Store and Protect Your Information?

  1. After receiving your PII, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

  2. If you are visiting the Site from outside of the USA, you understand that your connection may be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.

  3. Retention. We retain your personal information for as long as your account is active and as needed to provide our services. After account closure, we retain certain records as required by law. As a registered Money Services Business, federal regulations require us to retain certain customer identification and transaction records for a minimum of five (5) years after account closure. We may also retain logs and other technical records as necessary for security, fraud prevention, and regulatory compliance. For information not subject to legal retention requirements, we will honor deletion requests within 30 days. We employ industry-standard security measures to protect all retained information.

How Do We Use Cookies And Other Network Technologies?

  1. To enhance your online experience with us, our web pages may presently or in the future use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies.

  2. Our Service may use Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. Google may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

  3. We and our service providers may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some of our Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of our Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.

  4. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We may use this information to improve our site.

  5. Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals.

Collection of Information by Others

Our Terms of Service document may identify certain third-party websites to which we may provide links, and that you may click on our Site or in our Service. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.

Credit Reports

Some of the personal information that we collect about you comes from third parties, and if those third parties are credit reporting agencies, then the Fair Credit Reporting Act of 1970, as amended by the Fair and Accurate Credit Transactions Act of 2003 (together, “FCRA”) may apply. If and to the extent that FCRA applies to our collection, use, disclosure, sharing, and storage of your personal information as described in this Privacy Policy, we certify that we will process your information in only accordance with our permissible purposes (as part of a business transaction that you have initiated and our legitimate business needs as described in this Privacy Policy); we will notify you if and when any negative adverse actions are taken against you; and we will destroy your information in a way that prevents unauthorized access or use.

If FCRA applies to your information, you have the right to request that information from us; to correct or delete inaccurate information; and to know which credit reporting agency provided us with your information.

BY USING THE SERVICE, YOU SPECIFICALLY CONSENT TO OUR COLLECTION, USE, SHARING, DISCLOSURE, SHARING, AND STORAGE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Children and Young People's Information

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the Children's Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our Services, or wish to remove your child's PII from our servers, please contact us at [email protected]. Our Site will not knowingly accept PII from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at [email protected].

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your personal information:

  • Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties with whom we share it.
  • Right to Delete: You may request deletion of personal information we have collected, subject to certain exceptions, including our legal obligation to retain records under the Bank Secrecy Act.
  • Right to Correct: You may request correction of inaccurate personal information.
  • Right to Opt-Out of Sale: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at [email protected] with "California Privacy Request" in the subject line. We will respond within 45 days of receiving your verifiable request.

Nevada Privacy Rights

If you are a Nevada resident, we do not “sell” your “covered information” as such terms are defined in the Nevada Privacy of Information Collected on the Internet from Consumers Act as amended by Nevada Revised Statutes Chapter 603A (“Nevada Privacy Law” or “NPL”). Though we do not sell your covered information, as someone that is subject to the NPL, you have a right of access in relation to the covered information of yours that we have or process, including why we process it, and other parties with whom we may share such information. If you would like to tell us not to sell your information in the future, please email us at [email protected] with your name, postal address, telephone number, and email address with “Nevada Do Not sell” in the subject line.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us at:

Magnolia Financial Services, Inc. 999 Peachtree St NE, Suite 300 Atlanta, GA 30309 United States ATT: Compliance Officer Email: [email protected]