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PRIVACY POLICY

LAST UPDATED: OCTOBER 2021

This Privacy Policy (“Policy”) covers the following affiliated companies in the
M1 family of companies: M1 Holdings Inc., M1 Finance LLC, M1 Advisory Services
LLC, and M1 Spend LLC. Theses entities are collectively referred to as “M1,”
“affiliated companies,” “we,” “us,” and “our” throughout this Policy.

Overview

We are committed to maintaining the privacy and confidentiality of our
customers’ personal information. In the course of offering and providing
financial products and services, we collect and maintain certain personal
information about you. This information can come from information you provide on
applications or other forms, through your inquiries by mail, e-mail, or
telephone, or by other means.

This policy explains what personal information we collect and how we use and
share such personal information. It also explains what you can do to limit the
use and sharing of your personal information. We do not disclose personal
information about our customers to non-affiliated third parties, except as
described below.

Online Privacy

M1 Finance may periodically collect information from you through automated
means. When you browse our site, use the iOS and Android applications, use our
services, or read our emails or newsletters, we may use “cookies” or other
online tracking mechanisms (including pixel tags, web beacons, clear GIFs and
device fingerprints) in order to provide better service, facilitate your use of
the site or services, store online preferences, track usage of the site or
services, tailor the marking of business services, or enhance security. M1 does
not store login credentials used to link Account information.

Some of our cookies are used for web analytics and intelligence about our site.
We may also use web beacons or other technologies for similar purposes and we
may include these in marketing email messages or our newsletters in order to
determine whether messages have been opened and links clicked on. Web beacons do
not place information on your device but may work in conjunction with cookies to
monitor online activity.

By using our site or applications you agree that we can place cookies on your
device and use other online tracking mechanisms as explained in this privacy
notice.  You may be able to control your acceptance of cookies and similar
technologies on a website, and most devices and browsers offer their own privacy
settings for cookies. You will need to manage your cookie settings for each
device and browser you use. If you do not accept cookies, you may experience
some inconvenience in your use of some sites and online products. For example, a
website may not be able to recognize your device and you may need to answer
challenge questions or provide additional information each time you log on.

To help us protect against fraud, provide our services to you, and improve our
services, we collect location data, including current and historical information
concerning a user’s geographic location, GPS location, transaction location, and
IP addresses that are used in conjunction with our services. We collect your
precise location data with your permission, and use that information, for
example, to help protect against fraud by detecting and declining debit card
transactions that may occur far away from your device’s location. You may
decline to allow us to collect such geolocational information, in which case M1
may not be able to provide certain features or functionalities to you.

We also may obtain information on the device you use, including the Universally
Unique Identifier, advertising identifier (“IDFA” or “AdID”), operating system
and version, wireless carrier, and network type. This information is used to
identify customer device issues and for marketing purposes.

If you subscribe to any of our newsletters , we will use your name and email
address to send the newsletter to you. You can unsubscribe at any time following
the instructions at the bottom of these emails or you can contact us at the
information below. We also may collect information from you derived or resulting
from voluntary surveys.

By providing your phone number you expressly consent to M1 and/or its agents
calling or texting you using an automated telephone dialing system and/or
prerecorded messages, even if you incur charges for receiving such
communications. You may request to be removed from phone or text communications
by emailing privacy@m1finance.com or informing the agent that contacts you.

We may access your contact list, with your permission, on your mobile device or
in your email accounts so that you can identify your contacts using our services
and direct the invitation of your contacts for our services. We store and use
this information to suggest referrals or connections and for other reasons
related to our services.

Interest-based advertising

We use “interest-based” ads, which are known as “online behavioral advertising.”
We may partner with ad networks and other advertising providers (“Advertising
Providers”) who serve ads on behalf of us and others on non-affiliated sites.
Some of these third parties may use cookies and other technologies to collect
information about your online activities over time and across third party
websites or online services to deliver advertising based on your interests and
preferences, as inferred from your browsing history. Some of these ads may be
personalized, meaning that they are intended to be relevant to you based on
information that M1 and its Advertising Providers collect about your visits to
this site and elsewhere over time.

We may use third-party analytics services (for example, we use Google Analytics,
Facebook, and others) to evaluate your use of the platform, compile reports on
activity, analyze performance metrics, and collect and evaluate other
information relating to the platform and mobile and internet usage. For more
information on these third parties, including how to opt out of certain data
collection, please visit www.google.com/analytics. Please be advised that if you
opt out of any of these services, you may not be able to use the full
functionality of the platform. Additionally, all browsing information is
collected in the aggregate, de-identified and anonymized.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. At this time, we do not recognize or respond to DNT signals.

Protecting information

With regard to our internal security procedures, we restrict access to your
personal and account information to those employees who “need to know” the
information in order to provide products and services to you. We maintain
reasonable physical, administrative, and technical safeguards to protect your
personal information. We conduct regular internal audits of our business
practices and procedures in order to protect your personal information.

We may also disclose your personal information as required by law, such as to
comply with a subpoena, or similar legal process and when we believe in good
faith that disclosure is necessary to protect our rights, protect your safety or
the safety of others, investigate fraud, or respond to a government request.

Third Party Services

We use Plaid Inc. (“Plaid”) to gather End User’s data from financial
institutions. By using our service, you grant us and Plaid the right, power, and
authority to act on your behalf to access and transmit your personal and
financial information from the relevant financial institution. You agree to your
personal and financial information being transferred, stored, and processed by
Plaid in accordance with the Plaid Privacy Policy.

If you choose to apply for an M1 Visa™ debit card, you understand that such card
is issued by Lincoln Savings Bank and you agree to comply with Lincoln Savings
Bank’s privacy policy.

If you choose to apply for The Owner’s Reward Credit Card by M1, you understand
that such card is powered by Deserve and issued by Celtic Bank, and you also
agree to comply with Deserve’s privacy policy and Celtic Bank’s privacy policy.

If you choose to use M1 Instant Help chatbot, you understand the chatbot is
provided by M1 in partnership with Ada Support Inc. and you agree to comply with
Ada Support Inc.’s privacy policy.

Retention of Your Information

We will retain your personal information for as long as it serves the
purposes(s) for which it was initially collected as stated in this Privacy
Policy, or subsequently authorized. We will also retain and use personal
information as necessary to comply with our legal obligations, resolve disputes,
or enforce our agreements. If you are no longer a customer, we will not destroy
your information unless required or permitted by law. We will continue to treat
your personal information in accordance with this privacy policy and applicable
laws.

Information connected to you that is no longer necessary and relevant to provide
our services may be aggregated with other non-personal data to provide insights
which are commercially valuable to M1, such as statistics of the use of M1
Services.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age
of 18 on our services. In the event that we learn that we have inadvertently
collected personal information from a child under age 18, we will take
reasonable steps to delete this information. If you believe that we might have
any information from a child under 18, please contact us at
privacy@m1finance.com.

California Privacy Rights

If you are a California resident, California law requires us to provide you with
some additional information regarding how we collect, use and share your
“personal information” (as defined in the California Consumer Privacy Act
(“CCPA”)), other than the personal information we collect in connection with
providing financial products and services. The CCPA, however, does not apply to
all M1 entities.

Depending on how you interact with our website and services, we may collect the
following categories of personal information about you, in addition to the
information we collect in connection with providing financial products and
services:

 * Identifiers, such as your name and contact information, IP address, and
   mobile device identifiers
 * Internet usage information, such as browsing history, access history, and use
   and interaction with our website.

This information is used and disclosed for the purposes and to the categories of
third parties described in the main privacy policy, above.

Your California Privacy Rights

If you are a California resident, you may have certain rights. California law
may permit you to request that we:

 * Provide you the categories of personal information we have collected or
   disclosed about you in the last twelve months; the categories of sources of
   such information; the business or commercial purpose for collecting or
   distributing your personal information; and the categories of third parties
   with whom we shared personal information.
 * Provide access to and/or a copy of certain information we hold about you.
 * Delete certain information we may have about you.

We do not sell Personal Information to third parties. We do allow third parties
to collect personal information through our service and share personal
information with third parties for the business purposes described in this
Privacy Policy, including without limitation advertising and marketing on our
service and elsewhere based on users’ online activities over time and across
different sites, services, and devices.

California law permits consumers to request, once per year, that we disclose the
identity of any third parties with whom we have shared personal information for
the third parties’ direct marketing purposes within the previous calendar year,
along with the type of personal information disclosed. Please contact
privacy@m1finance.com for such requests.

Updates to this Policy

As required by federal law, we will notify you of our privacy policy annually.
We reserve the right to modify this policy at any time. If we do change it, we
will revise the “Effective Date” above and post the new policy. To stay informed
of our privacy practices, we recommend you review this Policy on a regular basis
as you continue to use our Services.

Contact Us

For questions about our policy, or for additional copies of this notice, please
email us at privacy@m1compliance.com.

FactsWhat does M1 Holdings Inc. do with your personal information?Why?Financial
companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law requires us
to tell you how we collect, share, and protect your personal information. Please
read this notice carefully to understand what we do.What?The types of personal
information we collect and share depend on the product or service you have with
us. This information can include:
•      Social Security Number and income
·      Account balances and transaction history
·      Investment experience and checking account information

When you are no longer our customers, we continue to share your information as
described in this notice.How?All financial companies need to share customers’
personal information to run their everyday business. In the section below, we
list the reasons financial companies can share their customers’ personal
information; the reason M1 chooses to share; and whether you can limit this
sharing.

Reasons we can share your personal informationDoes M1 Holdings Inc. share?Can
you limit this sharing?For our everyday business purposes –
such as to process your transactions, maintain your account(s), respond to court
orders and legal investigations, or report to credit bureausYESNOFor our
marketing purposes — To offer our products and services to youYESNOFor joint
marketing with other financial companiesNOWe don’t shareFor our affiliates
everyday business purposes — information about your transactions and
experiencesYESNOFor our affiliates’ everyday business purposes — information
about your creditworthinessNOYESFor our affiliates to market to youYESYESFor
nonaffiliates to market to youNOWe don’t share

To limit our sharing

Email us at privacy@m1finance.com.

Please note:

If you are a new customer, we can begin sharing your information 30 days from
the date we sent this notice. When you are no longer our customer, we continue
to share your information as described in this notice.

However, you can contact us at any time to limit our sharing

Questions?

Email us at privacy@m1finance.com.

Who we areWho is providing this notice?M1 Holdings Inc. (also “M1”) and its
affiliates. See list of affiliates below.

What we doHow does M1 collect my personal information?We collect your personal
information, for example, when you:
• Open an account or give us your income information,
• Seek information about your investment or retirement portfolio,
• Make deposits or withdrawals from your account.

We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies.How does M1 protect my personal information?To
protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.Why can’t I limit all
sharing??Federal law gives you the right to limit only:
• Sharing for affiliates’ everyday business purposes – information about your
creditworthiness
• Affiliates from using your information to market to you

State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under certain state laws.What happens
when I limit sharing for an account I hold jointly with someone else??Your
choices will apply to everyone on your account.

DefinitionsAffiliatesCompanies related by common ownership or control. They can
be financial and nonfinancial companies.

Our affiliates include companies with a M1 name; financial companies such as M1
Finance LLC and M1 Advisory Services LLC; nonfinancial companies such as M1
Holdings Inc. and M1 Spend LLC.NonaffiliatesCompanies not related by common
ownership or control. They can be financial and nonfinancial companies.

M1 does not share with nonaffiliates so they can market to you.Joint marketingA
formal agreement between nonaffiliated financial companies that together market
financial products or services to you.

M1 doesn’t jointly market.

Other important informationState and International Laws

For Vermont Residents: In accordance with Vermont Laws, we will not share
information we collect about Vermont residents with companies who are not
affiliates, except as permitted by law, such as with your consent or to service
your accounts. We will not share information about your creditworthiness with
our affiliates without your authorization or consent, but we may share
information about our transactions or experiences with you with our affiliates
without your consent.

For Nevada Residents: Nevada law requires us to disclose that you may request to
be placed on M1’s internal “do not call” list at any time by calling (312)
600-2883, and that we are providing this notice to you pursuant to state law,
and that you may obtain further information by contacting the Nevada Attorney
General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone
702-486-3132; email BCPINFO@ag.state.nv.us.

For California Residents: In accordance with California law, we will not share
information we collect about you with nonaffiliates, except as allowed by law.
For example, we may share information with your consent or to service your
accounts. Among our affiliates, we will limit information sharing to the extent
required by California law.

Check the background of M1 Finance LLC on FINRA's BrokerCheck

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By using this website, you accept our Terms of Use and Privacy Policy and
acknowledge receipt of all disclosures in our Disclosure Library. All agreements
are available in our Agreement Library. M1 relies on information from various
sources believed to be reliable, including clients and third parties, but cannot
guarantee the accuracy and completeness of that information.

M1 refers to M1 Holdings Inc., and its affiliates. M1 Holdings is a technology
company offering a range of financial products and services through its
wholly-owned, separate but affiliated operating subsidiaries, M1 Finance LLC and
M1 Spend LLC.

M1 Plus is an annual membership that confers benefits for products and services
offered by M1 Finance LLC and M1 Spend LLC.

All investing involves risk, including the risk of losing the money you invest.
Past performance does not guarantee future performance. Using M1 Borrow’s margin
account can add to these risks, and you should review our margin account risk
disclosure before borrowing. Nothing in this informational site is an offer,
solicitation of an offer, or advice to buy or sell any security and you are
encouraged to consult your personal investment, legal, or tax advisors.

Brokerage products and services are not FDIC insured, no bank guarantee, and may
lose value. Brokerage products and services are offered by M1 Finance LLC, an
SEC registered broker-dealer, Member FINRA / SIPC.

Commission-free trading of stocks and ETFs refers to $0 commissions charged by
M1 Finance LLC for self-directed brokerage accounts. Other fees may apply such
as regulatory, M1 Plus membership, account closures and ADR fees. For complete
list of fees, visit M1 Fee Schedule.

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M1 is not a bank. M1 Spend checking accounts furnished by Lincoln Savings Bank,
Member FDIC. M1 Visa® Debit Card is issued by Lincoln Savings Bank, Member FDIC.

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Credit Card not available for US Territory Residents. Review Cardholder
Agreement and Rewards Terms for important information about the Owner’s Rewards
Card by M1. The Owner’s Rewards Card by M1 is Powered by Deserve and issued by
Celtic Bank, a Utah-Chartered Industrial Bank, Member FDIC.

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M1 Digital LLC is a wholly separate affiliate of M1 Finance LLC, and neither are
involved with the execution or custody of cryptocurrencies. Cryptocurrencies are
not FDIC or SIPC insured. For relevant crypto disclosures and risks, visit
Crypto Disclosures.

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All product and company names are trademarks™ or registered® trademarks of their
respective holders. Use of them does not imply any affiliation with or
endorsement by them.

App Store is a service mark of Apple Inc. Google Play and the Google Play logo
are trademarks of Google LLC.

200 N LaSalle St., Ste. 800 Chicago, IL 60601

© Copyright 2022 M1 Holdings Inc.

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