Privacy Policy

Last updated: January 29, 2025

NCC-1701-D Inc (dba Mora Financial) provides access and services related to custodial minor Roth IRA retirement accounts, College 529 savings plans, and other minor investment accounts by and/or through affiliated companies, Mora Advisors LLC., and other affiliated companies (collectively referred to as “Mora” “we,” or “us”). , as well as unaffiliated third party platforms and issuers of private securities. For information about the services provided by Mora Financial, please see Mora.com (the “Site”). As part of the process of providing our services, we are committed to protecting your privacy concerning the personal information (“PI”) we may collect about you. We do not sell your PI to third parties, but we may share it with third parties as necessary to provide our services and as otherwise provided under this Privacy Policy. This notice describes our current privacy practices. For as long as we have your PI, we will protect it pursuant to this policy.¹

Information We Collect through the Mora Financial Platform

The type of PI we collect includes the following:

• When you complete forms, applications, or instructions; visit our website; or speak with one of our representatives, you give us information that may include:

• Your name, address, date of birth, social security number, driver’s license number, email address, certain pre-existing IRA or qualified plan account information, personal financial information and other non-public information.

• Similar information about your spouse, children or other family members.

• Additional information from you or third parties to validate or supplement this information.

• Payment information, such as credit card, bank account, or other account information.

• Suitability information on your investment expectations, risk tolerance and goals that allows us to prepare an IPS for you, as required by the Investment Advisors Act, 1940 and amendments thereof.

• We may collect information from other sources, such as consumer reporting agencies to verify information we receive from you.

• Non-personal data, such as information collected through cookies,² number of visits to our Site, and domain names of your internet service provider.

Except to the extent required by law, your use of Do Not Track features in your browser will not affect our collection of information.

Use and Disclosure of Your Personal Information

We may share your PI within our company, with our Custodian(s) that custody your account(s), with affiliates, third parties with whom we have contracted in furtherance of our business, and with those third parties you have authorized us to share such information. We or they use this information for identification purposes, to execute transactions, to communicate with you, to operate our systems, to market on our behalf, to identify investment opportunities that may interest you or be available to you, to provide customer service, or to analyze in order to enhance our services.

Your PI will be passed to our Custodian Charles Schwab to open relevant Investment Accounts that you specify. They shall save and process your PI in accordance with their own privacy policies, which you can view here https://www.schwab.com/legal/privacy-overview

We require our service providers to protect the PI about you that they receive from us and to use or disclose it only for the work they perform for us, or as permitted by law. However, information we obtain from reports prepared by service providers may be kept by the service providers and shared with other persons. Further, the use of any PI you provide directly to any third party service or site accessible through us or the Site is governed by such third party’s policies and terms of use, not ours. We also may provide information to regulatory authorities, law enforcement officials and to others when we believe in good faith that the law requires disclosure, or such disclosure is permitted to protect ourselves or others from harm or wrongdoing. You may opt out of receiving marketing communications in accordance with applicable law or limit the sharing of PI with unaffiliated third parties for marketing purposes. To limit marketing communications or the sharing of PI with unaffiliated third parties for marketing purposes, please see the “contacting us” section below.

Security of Information

We have an important responsibility to keep your information safe. We use physical, electronic and procedural safeguards to protect your information from unauthorized disclosure such as SSL, 256-bit AES encryption, regular datacenter backups, security reviews and more. Our employees are trained and authorized to access your information only when they need it to provide you with services. We limit the access we have to your investment accounts held at our Custodian to limit potential damage from a cybersecurity breach or unauthorized access. Employees who have access to your PI are required to keep it confidential. Employees are trained on the importance of data privacy. When we share PI with third parties for the purposes noted above, we ensure there are contractual restrictions on their use and disclosure of that information. Please be mindful that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Your Rights Regarding your Personal Information

• Accuracy of Information: We strive for accurate records. Please tell us if you receive any incorrect materials from us or if you feel the PI we have about you is inaccurate, incomplete, or not current by emailing us at the below address. We will correct any inaccurate or outdated information as soon as possible.

• Access: We will tell you what PI we have about you that we are required by law to provide to you at your request (“Disclosable PI”). Upon written, email or phone request, you may obtain a copy of the Disclosable PI within 45 business days (or such shorter period required by law, if any). We will not provide you with information we have collected in connection with, or in anticipation of, a claim or legal proceeding.

Contacting Us

To notify us about opting out as described above or if you have any questions about this privacy policy, please contact us by emailing benji@mora.com, calling (341) 206-3396, or writing to:

Updates and Amendments

We may update or amend our privacy policy from time to time. We will notify you and/or deliver policy changes to you to the extent required by law, and any revised policy will be posted to the Site.

1) If a state’s privacy laws are more restrictive than those stated in this notice, and such laws are applicable to the Services provided by Mora Financial, we will comply with those laws. If you work with an agent, consultant and/or advisor who utilizes our services on your behalf, they may have a different privacy policies governing the use of PI.

2) We may use a technology called “cookies.” A cookie is a piece of information that the computer hosting our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For example, we use cookies when you log in to an account to ensure you are authenticated in all the screens you interact with and so we do not need to ask you for your password on each page. We also use cookies to ensure integrity of data across accounts. Once you log out or close your browser, this cookie expires and no longer has any effect. We also use longer-lasting cookies for purposes such as to pre-fill your e-mail address when you return to the Site. Users can control the use of cookies at the individual browser level. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please note that if you turn cookies off it may limit your use of the Site.

3) For example, we use Google Analytics, which may collect information including but not limited to your browser history, cookies, and/or IP address when you interact with the Site or our applications. For more information on how Google collects and processes and safeguards this data, visit Google’s disclosures and information at https://policies.google.com/technologies/partner-sites and  https://support.google.com/analytics/answer/6004245.

We may also convert PI into general information by excluding information that is personally identifiable. General information may include cookies, tags, scripts, Internet service providers, and other system information. Mora Financial or its service providers may use such general information in order to analyze trends, administer the Site, and track visitor and user movement to, from and around the Site. General information is the property of Mora Financial and Mora Financial has the right to use such general information as it determines in its sole discretion.