GLBA Privacy Notice

This notice is provided jointly by SIMPLE MONEY ADVISORS LLC and its parent, Simple Money, Inc. (together, “Simple Money,” “we,” “us,” or “our”) pursuant to the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations. It describes how we collect, use, share, and protect the nonpublic personal information (“NPI”) of consumers, clients, and former clients.

SIMPLE MONEY ADVISORS LLC is a wholly owned subsidiary of Simple Money, Inc. Both entities are located at 131 Continental Dr, Suite 305, Newark, DE 19713 US. Investment advisory services are provided only by SIMPLE MONEY ADVISORS LLC, an investment adviser registered with the State of California and regulated by the California Department of Financial Protection and Innovation. It is not registered with the U.S. Securities and Exchange Commission and provides advisory services only where registered or otherwise permitted to do so. Simple Money, Inc. owns and operates the software platform and is not an investment adviser or broker-dealer.

1. Categories of Information We Collect

We collect the following categories of nonpublic personal information:

• Information you provide directly: Name and contact information; household and family information; income, expenses, assets, liabilities, investment objectives, risk tolerance, tax-related information, planning assumptions, communications, meeting records, and documents you choose to provide.
• Information from account connections: When you connect financial accounts through Plaid, we receive account balances, transaction history, investment holdings (including tickers, quantities, cost basis, and current values), liabilities (including interest rates and payment schedules), and account identifiers.
• Information collected automatically: Device information, IP address, browser type, and usage data collected through analytics tools to improve the Service.

2. Information We Share

We do not share your nonpublic personal information with non-affiliated third parties for their own marketing purposes or for any purpose other than as described below.

We disclose NPI only to service providers who perform services on our behalf and who are contractually obligated to use your information solely for providing those services. These include:

• Plaid Inc.— financial data aggregation (connecting your bank and brokerage accounts)
• Supabase— database hosting and authentication
• Vercel— application hosting
• Google Gemini— AI-powered financial insights and recommendations
• PostHog— privacy-focused product analytics (receives only anonymized usage data, no PII)
• Upstash— rate limiting and security

We do not sell or rent your nonpublic personal information to anyone.

3. Affiliated Companies

SIMPLE MONEY ADVISORS LLC is a wholly owned subsidiary of Simple Money, Inc. We may share NPI between these affiliated companies as permitted by law to provide technology and advisory services, administer and support client relationships, operate and secure our business, manage risk, and comply with legal and regulatory obligations. Our affiliates do not use NPI received from us to market unrelated products or services.

4. Former Customers

If you close your account or become a former customer, we will continue to adhere to the practices described in this notice with respect to any NPI we have retained. We do not share former customers' NPI with non-affiliated third parties except as described in Section 2 above.

5. Opt-Out Rights

Because we do not share your NPI with non-affiliated third parties for purposes other than servicing your account (as described in Section 2), federal law does not require us to provide you with an opt-out right. If our information-sharing practices change in the future, we will update this notice and provide you with opt-out rights as required by law.

6. How We Protect Your Information

We maintain administrative, technical, and physical safeguards to protect your nonpublic personal information, including:

• Encryption at rest: Sensitive fields (including Plaid access tokens, email addresses, and account identifiers) are encrypted using AES-256-GCM with versioned keys.
• Encryption in transit: All data transmitted between your browser, our servers, and our service providers is encrypted using TLS. Database connections require SSL in production.
• Access controls: Row Level Security (RLS) policies enforce that each user can only access their own data. All data access is scoped by authenticated user identity.
• Audit logging: We maintain logs of data access and modifications for security monitoring.
• Rate limiting: API endpoints are rate-limited to prevent abuse.

No security system is completely impenetrable. While we strive to protect your data using industry-standard measures, we cannot guarantee absolute security.

7. Changes to This Notice

We may update this GLBA Privacy Notice from time to time. If we make material changes to how we share your NPI, we will notify you by updating this page and, where required by law, providing you with a revised notice before implementing the changes. We encourage you to review this notice periodically.

8. Contact Us

If you have questions about this notice or our privacy practices, please contact us at:

SIMPLE MONEY ADVISORS LLC and Simple Money, Inc.
131 Continental Dr, Suite 305
Newark, DE 19713 US
Email: vb@thesimplemoney.com