Privacy Policy

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Franklin Yielder Effective Date: March 13, 2026 Last Updated: March 13, 2026

Franklin Capital ("we," "us," or "our") operates the Franklin Yielder mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

By using the App, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the App.

When you register for an account or use our services, we may collect:

• Identity Information: First name, last name, email address, and phone number.
• Accreditation Information: Investor type (individual or entity), accreditation method (income, net worth, professional certification, or entity assets), entity name, and entity type.
• Authentication Credentials: Password (stored in hashed form; we never store or have access to your plaintext password).

To facilitate investments and redemptions, we may collect:

• Bank Account Details: Bank name, ABA routing number, account number, and account type (checking or savings), entered manually by you.
• Linked Bank Accounts: When you choose to link your bank account through our third-party partner Plaid, we receive limited account information such as the institution name, account name, account mask (last four digits), and account type.
• Investment Data: Investment amounts, transaction history, interest earned, redemption requests, and related financial records.

We may automatically collect:

• Device Information: Device type, operating system, and unique device identifiers.
• Usage Data: App interaction data, feature usage, and session information.
• Biometric Authentication Preferences: If you choose to enable Face ID or fingerprint authentication, we store your preference locally on your device. We do not collect or store your biometric data on our servers.

We use the information we collect to:

• Create and manage your account.
• Verify your accredited investor status.
• Process investments, calculate interest, and facilitate redemptions.
• Link your bank account for ACH transfers and fund disbursements.
• Communicate with you regarding your account, transactions, and support inquiries.
• Provide customer support through our in-app messaging system.
• Maintain and improve the App's functionality, security, and performance.
• Comply with legal and regulatory obligations.

We use Plaid Inc. ("Plaid") to enable you to securely link your bank account. When you connect your bank through Plaid, you authorize Plaid to access certain financial information from your financial institution. Plaid's use of your data is governed by the Plaid End User Privacy Policy. We receive only limited account details (institution name, account mask, and account type) from Plaid.

We may engage trusted third-party service providers for hosting, data storage, analytics, and communication services. These providers are contractually obligated to protect your information and may only use it to perform services on our behalf.

• Your personal and financial information is stored on secure servers with access controls and encryption in transit (TLS/SSL).
• Passwords are cryptographically hashed and are never stored in plaintext.
• Bank account numbers are stored with access restricted to authorized services only. Account numbers are masked (showing only the last four digits) whenever displayed in the App or returned through our API.
• We implement administrative, technical, and physical safeguards designed to protect your information. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

We do not sell, rent, or trade your personal information to third parties. We may share your information only in the following circumstances:

• Service Providers: With trusted vendors who assist in operating the App, subject to confidentiality obligations.
• Legal Compliance: When required by law, regulation, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, in which case your information may be transferred as part of the transaction.
• Protection of Rights: To enforce our terms, protect our rights, safety, or property, or the rights, safety, or property of others.

We retain your personal information for as long as your account is active or as needed to provide you services. We may also retain your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. When your data is no longer needed, we will securely delete or anonymize it.

Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate or incomplete information.
• Delete your account and associated personal information, subject to legal retention requirements.
• Withdraw Consent for optional data processing activities.
• Opt Out of non-essential communications.

To exercise any of these rights, please contact us using the information provided below.

The App is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have inadvertently collected information from a child under 18, we will promptly delete it. If you believe a child has provided us with personal information, please contact us.

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last Updated" date at the top of this policy. We encourage you to review this policy periodically. Your continued use of the App after any changes constitutes your acceptance of the updated policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Franklin Capital Email: support@franklinyielder.com

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your rights, contact us at the email address above.

If you are accessing the App from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located. By using the App, you consent to the transfer of your information to the United States.