Musaffa Privacy Policy

Your privacy is important. This Privacy Policy explains how Musaffa, LLC and its Affiliates (“Musaffa”, “us”, “we” or “our”) handles your personal information in connection with the website, application (including a mobile application), product, or service that links to this Privacy Policy and administration of the recruiting process through our websites (we call these our “Services”). It applies generally to the following groups:

• Customers and users (including prospective customers and users);
• Job Applicants for open positions at Musaffa;
• Third party business partners; and
• Other individuals who interact with us or whose personal information we maintain.

This Privacy Policy does not apply to any website, application, product, or service that links to its own privacy policy or that is offered by third parties, in which clicking on third party links or enabling those connections may allow the third party to collect, use, or share data about you. We encourage you to read their respective privacy policies.

By using our Service, you represent and warrant that you are the legal age of majority under applicable law (generally the age of 18 or older) to form a binding contract with Musaffa and meet the eligibility requirements. If you are under the legal age of majority under applicable law, you represent to Musaffa that you have obtained a parent/guardian’s consent and that your parent/guardian has reviewed and agreed to this Privacy Policy prior to using the Service. If you are an employee of a company or other entity or are acting on behalf of a company or entity, you must be authorized to accept this Privacy Policy on behalf of that employer, company, or entity. If you do not meet these requirements, you must not access or use our Service.

This Privacy Policy is incorporated by reference in our Terms of Use, which is binding on all our customers, prospective customers, our customers’ customers (both direct and indirect), partners, resellers, and visitors to or users of our websites, applications, and Services. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Who is Musaffa and how can you contact us?

Musaffa is a US-based company, and Musaffa’s group of companies is made up of several legal entities with offices located across the globe, including Musaffa, Inc., and Musaffa Financial Solutions LLC (“Affiliates”). Please see the list of locations here.

Musaffa acts as a controller of your personal information where we determine how and why personal information can be used, and Musaffa’s company that provides the specific Service (as identified therein) is the primary controller of your personal information. This Privacy Policy, however, does not apply where we act as a processor or service provider to another controller (such as our customers).

What personal information do we collect and process?

Mandatory information

Non-mandatory information

We may collect your phone number and email address for the purpose of sending a One-Time Password (“OTP”) via SMS, WhatsApp, voice, email, or authenticator apps to verify your identity. This process is designed to enhance the security of your account and ensure that only authorized users can access our Services. This OTP is stored in an encrypted manner on our systems.

A note on children’s online privacy.

How do we collect personal information?

Direct Interactions: You provide your personal information when you interact with us, such as when you register for Services, fill in forms, communicate with us, and apply for open positions in Musaffa.

User Contributions: We collect your personal information when you or others upload, share, send, or input that information through our Services or networks, or when you or they communicate with us.

Automatically: We automatically collect personal information about you when you interact with us, such as when you use our Services, visit our offices or events, open emails or view advertisements from us, or communicate with us. We may collect some of this personal information by using cookies and other similar technologies, and we recommend you review our Cookie Notice for more information.

Third Party or Publicly Available Sources: We may receive your personal information from third parties, such as our third party business partners (including data brokers and advertising partners), your organizations, governmental agencies who publish public records, and other publicly or generally available sources (including online websites). For more information on third party service providers, you may refer to Cookie Notice

How do we use personal information?

This section includes details of the purposes for which we use personal information and the different legal reasons (also called legal basis) for processing that personal information.

Who do we share personal information with?

• Affiliates within Musaffa group of companies.
• Third party business partners (also known as “data processors”) that support our business, such as our content and other partners, vendors and subcontractors, analytics providers, advertising and marketing agencies, credit agencies, and other third parties we engage.
• With governmental agencies and third parties involved in our sale or purchase of a business or assets, including in connection with a merger, divestiture, restructuring, reorganization, bankruptcy, liquidation, dissolution, or other disposition of assets.
• With law enforcement, government agencies, or other third parties in order to comply with any law, court order, legal request, or other legal process, as well as to enforce our agreements or protect the rights, property, or safety of our business, employees, customers, or others (including for the purposes of cybersecurity, fraud protection, and credit risk reduction).
• With others when necessary to fulfill your consents or to follow your instructions.

Where do we store personal information?

As described above, we are a global organization so your personal information may be transferred outside of your home country and may be stored in and accessed from multiple countries, including the United States. When you interact with us, you authorize us to transfer your personal information outside of your home country and you acknowledge the risk that we may transfer your personal information to countries that may provide less protection than your home country’s privacy laws and we may not be able to prevent government authorities in some countries from accessing your personal information.
Musaffa will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

What steps do we take to secure personal information?

We work to implement technical and organizational measures designed to protect the security of personal information. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee its absolute security. To enhance the security of your personal information, we employ https protocols and ensure the data is encrypted during transmission. The security of your information also depends on you: you are responsible for using unique, strong usernames and passwords for each of your accounts, and for keeping those usernames and passwords confidential. We are not responsible for the circumvention of any privacy settings or cybersecurity measures contained on our Services, and any transmission of personal information is at your own risk. To help us continue to protect your personal information, you should always contact us via email at privacy@musaffa.com if you suspect that your personal information may have been compromised.

International Data Transfers

Your personal information will be processed in accordance with this policy in the U.S. and Europe. If you reside in Europe, we may process your personal information outside of the European Economic Area (“EEA”), and where we facilitate access to or transfer of your personal information outside of the EEA we will take steps to handle your personal information subject to appropriate safeguards, such as using approved standard contractual clauses where appropriate as the laws regarding processing of personal information may be less stringent than the laws in the EEA. Third parties that we work with may also process your personal information in the U.S. and/or facilitate the transfer of or access to your personal information outside of the U.S. In such cases, we will take steps to require them to process your personal information subject to appropriate safeguards, such as using standard contractual clauses where appropriate.

How long do we retain personal information?

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or until you submit a verifiable request for deletion, in accordance with applicable data protection laws and regulations. Under some circumstances, we may anonymize your information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified personal information for any legitimate business purpose without further notice to you or your consent.

What rights do you have over your personal information?

Your local privacy laws may grant you rights with respect to your personal information, and we will not knowingly discriminate against you because you have exercised any of your privacy rights. These rights differ based on the local laws that apply to you, but could include one or more of the following:

• Right to confirm we process your personal information and, if so, to access, correct, complete, opt out, object to or restrict the processing of, and delete certain personal information we hold about you, including the rights to receive your personal information in a portable copy. To submit a request, you can contact us via our email: privacy@musaffa.com.
• Right to delete your account, for which you may email us at support@musaffa.com requesting for deletion of your account or you may request deletion of your account from within the application (to delete from within the application please go to Profile Details > select Delete Account ). Please note that the Data Protection Officer may require you to verify your identity before proceeding with your request to delete your account. Any identity proof that you may provide shall be stored for a period of 6 months from the date of deletion of the account.
• To opt out of marketing emails from us, for which you may click the unsubscribe link at the bottom of each email that you receive from us.
• Nevada and Virginia residents and, beginning on July 1, 2023, Colorado and Connecticut residents and, beginning on December 31, 2023, Utah residents may also have the right to opt out of the use of their personal information for targeted advertising (including online behavior advertising) and/or opt-out of the sale of their personal information by emailing us at privacy@musaffa.com.
• California residents, under the California Consumer Privacy Act (“CCPA”), in addition to those indicated above, also have the right to know, refuse the sale of personal information, and/or the right to non-discrimination for exercising consumer privacy rights. See the section below entitled “Additional US State Privacy Rights.”
• E.U. residents,under the General Data Protection Regulation (“GDPR”), in addition to those indicated above, also have the right to request the erasure of personal data.

IMPORTANT: These rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfill your request. We are only required to honor these rights to the extent we act as a controller of that data and the requested rights have been granted and apply to you under applicable data protection laws. Please consult your local data protection laws to determine what rights may be available to you and when access to these rights is limited. You may appeal an adverse decision on your requests by emailing or writing to us at privacy@musaffa.com; and you have the right to lodge a complaint to your local regulator if you are not satisfied with our responses to your requests or how we manage your personal information. However, we encourage you to first email us at privacy@musaffa.com so we can address your concerns directly.

Additional US State Privacy Rights

This section provides additional details about the personal information we collect about California and Virginia residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Please note that the CCPA does not apply to what is referred to as nonpublic personal information collected by financial institutions, as that information is subject instead to other financial privacy laws. Additionally, the VCDPA does not apply to any entities that are financial institutions.

Subject to certain limitations and exceptions, the CCPA and VCDPA provide California and Virginia residents, respectively, with certain rights. Depending on the state in which you are a resident, you may have the right to:

• Confirm whether Musaffa processes your personal information;
• Correct inaccurate personal information;
• Request details (in a readily usable format) about the categories and specific elements of personal information we collect;
• Delete your personal information or account (for deleting your account please refer below for more details);
• Opt out of any sales, sharing, targeted advertising, or profiling for certain decisions (as these terms are defined in the CCPA and/or VCDPA); and
• Not be discriminated against for exercising these rights.

We do not sell information about you to third parties. In order to help Musaffa deliver advertising and marketing on other platforms, we do allow third parties to collect information through our Services. Please see the Cookie Notice for more details, including choices available to you.

We collect the following categories of personal information: identifiers (such as name, email address and IP address), Internet or other electronic network activity information (such as engagement with promotional messages and ads), and inferences (such as gender). For more details about the information we collect (including the categories of sources of this information) as well as the purposes for processing, please see the "What personal information do we collect and process" section above. We disclose this information with the categories of third parties described in the "Who do we share personal information with" section above.

California and Virginia residents may make a request to exercise rights under the CCPA and VCDPA, respectively, that are not otherwise exempt under applicable law. You may also request assistance or exercise your rights according to CCPA and VCDPA by sending an email to privacy@musaffa.com.

If you are a Musaffa app user, you can request to delete your account, for which you may email us at support@musaffa.com requesting for deletion of your account or you may request deletion of your account from within the application (to delete from within the application please go to Profile Details > select Delete Account ). Please note that the Data Protection Officer may require you to verify your identity before proceeding with your request to delete your account. We may verify the request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly. If you are a Virginia resident and Musaffa is unable to satisfy your request to exercise a right available to you under the VCDPA, you are entitled to appeal our decision by emailing privacy@musaffa.com.

Changes to this Privacy Policy

This Privacy Policy is expected to change over time. We reserve the right to update it at any time, for any reason. We will notify you of changes to our Privacy Policy by updating the “Last Updated” date and posting the updated Privacy Policy on this page and, in some cases, we provide additional notice (such as adding a statement to our website or sending you a notification). Changes to this Privacy Policy are effective when they are posted on this page and your continued engagement with our Services after any such revisions indicates that you accept and consent to them, so please check our Privacy Policy periodically for updates.

If there are any differences between the English version of our Privacy Policy and a version translated in another language, the English version controls.

Supplementals to Privacy Policy

Depending on the specific Service you are using or specific interactions you have with us (such as when you apply for a job or work for us), we may provide different or supplemental privacy statements or notices that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements or notices apply to that specific Service or those specific interactions. Of note, please review these supplemental privacy statements

• For more information on our use of cookies and other automated technologies as well as interest-based advertising, please review our Cookie Notice

Privacy Policy for investment management and advisory services

Please review our privacy policy for investment management and advisory services here.

Musaffa Investment Advisory Services Privacy Notice

Last updated: April 20, 2026

Musaffa LLC and its Affiliates (collectively “Musaffa”, “we”, “us”, or “our”) are committed to protecting the personal information of their current and potential customers. This Musaffa Investment Advisory Services Privacy Notice (the “Privacy Notice”) sets out how we collect, use, transfer, store, and otherwise process information relating to individuals who access or use Musaffa’s investment advisory services, which includes (i) discretionary portfolio management (“Managed Portfolios”) and (ii) self-directed investment recommendations advisory services (“Recommendation Advisory Service”), collectively referred to in this Privacy Notice as the “Advisory Services”. Musaffa provides these Advisory Services primarily to individuals and other eligible clients through its proprietary Global Halal Investing Platform (the “Platform”), accessible via mobile application and web interface. This Privacy Notice applies to prospective, current, and former users of the Advisory Services (collectively, “Users”, “you”, or “your”). The Advisory Services enable Users to access market data, place and manage trades, monitor portfolios, use Managed Portfolios service, and use other features designed to support halal investment and trading activities.

This Privacy Notice applies to your use of the Advisory Services and supplements our Privacy Policy for Advisory Services-specific privacy matters. Our Privacy Policy supplements this Privacy Notice for any privacy-related matters not specifically addressed herein, including but not limited to general data collection practices, international data transfers, and where we store your personal information. To the extent any provision of the Privacy Policy is relevant to the Advisory Services but not expressly covered in this Privacy Notice, such provision is incorporated herein by reference. In the event of any conflict between the two documents regarding the Advisory Services, this Privacy Notice shall control.

Please read this Privacy Notice carefully to understand our policies and practices regarding your personal information and how we treat it. By interacting with our Advisory Services or providing us with your personal information, you agree to the collection, use, and sharing of your personal information as described in this Privacy Notice. This Privacy Notice may change from time to time. As our client, you will receive notifications if we make material changes to this Privacy Notice and our revisions or changes to this policy will be highlighted in such notifications. Your continued use of the Advisory Services after you receive notifications about material changes as described here is deemed to be acceptance of those changes. If you do not agree with any such modification, you should close your account and cease using the Advisory Services.

1. DEFINITIONS

Affiliates – Companies that directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with Musaffa LLC. The term "control" (including the terms "controlled by" and "under common control with") means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of a company, whether through the ownership of voting securities, by contract, or otherwise.

Our affiliates include Musaffa, Inc., Musaffa Financial Solutions LLC, and Musaffa Musaffa Financing Broker Co.

2. CHILDREN’S AND MINORS’ INFORMATION

Our Advisory Services are not intended for, and we do not knowingly collect or solicit any personal information from children under the age of 18. If we learn we have collected or received personal information from a child under 18 years old, we will take reasonable steps to delete that information. If you reasonably believe that we might have information from a child under 18 who is not authorized to open an investing account to use our Advisory Services, please contact us at privacy@musaffa.com.

3. PERSONAL INFORMATION WE COLLECT AND PROCESS

To provide you with access to the Advisory Services and comply with our legal and regulatory obligations, we collect various types of personal information. Some of this information is provided directly by you during the account registration and onboarding process, while other information is obtained automatically or from third parties.

1. Information you provide when you open an investing account. When you create an investing account or apply to open an investing account with us, we require certain personal information to verify your identity and comply with regulatory requirements. This may include:

   • Identity Data: your name, date of birth, marital status, social security number/tax identification number, government-issued identification documents, and other data on government-issued identification documents.
   • Contact Data: your email address, mailing address, and telephone number, and any other contact information you provide to us.
   • Financial Data: banking information, financial account numbers and/or balances, credit card numbers or information, sources of income information about your employment (including employer name and address).
   • Investment Profile Information: age group, income, net worth, tax information, investment objectives, investment knowledge and experience, investment time horizon, and source of wealth or funds, risk tolerance, anticipated withdrawal timeframe, and planned investment contributions.
   • Geographic Data: a country, state or province, city, and street address.
   • Account Registration Data: your username, password.

2. Information you provide for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks. To fulfill our KYC and AML obligations, we work with a specialized third-party provider, Onfido (an Entrust company), which performs identity verification and document checks on our behalf. For these purposes, Onfido collects and processes on our behalf:

   • Biometric Data: It extracts facial geometry data from selfies, photos, videos to verify your identity and detect and prevent fraud.
   • Device Data: It collects information about your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
   • Identity Data: It collects your government-issued documents, such as your passport, ID, driver’s license, or other government-issued ID, to verify your identity. It will also collect scans, photos, or videos of your identification documents.
   • Data extracted from documents: This includes the date of issue, expiry date, place of birth, and document number.
   • Regulatory Data: Onfido will search your name against any U.S. or international sanctions lists, including but not limited to the Specially Designated Nationals List of the US Office of Foreign Assets Control, the Most Wanted List of the US Federal Bureau of Investigation and Interpol, determine your Politically Exposed Person (PEP) status, and provide the results to us.
   • Verification Output Data: Onfido provides us with verification results, including identity confirmation outcomes, document authenticity assessments, liveness check results, fraud-risk indicators, reasons for any verification failures, and other relevant information generated during the identity verification process.

   During onboarding, you will be asked to verify your identity. Before proceeding with KYC, you will need to read, understand, and accept Onfido’s Facial Scan and Voice Recording Policy, Privacy Policy and Terms of Service. We may conduct ongoing or periodic monitoring and re-verification of your information throughout our customer relationship to comply with regulatory requirements, including anti-money laundering obligations, sanctions screening, and other compliance purposes.

3. Information we collect when you use, or apply to use, our Advisory Services or otherwise engage or communicate with us.

   • Profile Data: This includes your knowledge assessment results, your interests, preferences, feedback, survey responses, and any other content you elect to provide as part of your profile or in any reviews you make through the Advisory Services or emails, chats, or other communications sent to us.
   • Usage Information: We collect information about your activity on our Advisory Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.
   • Account History: We collect information about your subscription, account, purchases, or discounts.
   • Trade and Order Details: This includes financial instrument, quantity, price, time stamps, and order type.
   • Transaction history: This includes deposits, withdrawals, transfers, and settlement details.
   • Portfolio Information: This includes age group, assets held, balances, positions, and profit/loss, investment knowledge and experience, source of wealth or funds, risk tolerance, anticipated withdrawal timeframe, and planned investment contributions.
   • Location Data: We may collect the GPS location of your mobile device in accordance with your device permissions. You can stop the collection of this precise location information at any time. Google uses technologies to approximate your location, including IP address (review Google’s Privacy Policy located at https://policies.google.com/privacy to learn more about how they process this information).
   • Information Collected Through Tracking Technologies: We and our service providers also use technologies, including cookies and web beacons, and software development kits, to automatically collect certain types of usage and device information when you use our Advisory Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information and other similar information. For information about how to disable cookies, review section 8 of this Privacy Notice, and
   • Other Information You Provide: We collect additional personal information that you choose to provide us, such as via focus groups, survey responses, contests, sweepstakes, customer support, or other means.

   We may anonymize your personal information and use it for statistics. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Advisory Services feature. If we combine or connect non-personal statistical or technical data with personal information so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

4. OUR PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION

We have to have a legal basis to process your personal data. In the following table, we explain these legal bases below alongside the purposes for which we process your data. Please note that certain data processing activities are mandatory for regulatory compliance and legal obligations. Where we process your data based on "legal obligation" or "contractual necessity," you cannot opt out of such processing as it is required for us to provide the Advisory Services, comply with applicable laws and regulations, or fulfill our contractual obligations to you.

In addition to the purposes outlined in the table above, the following activities are conducted as part of our mandatory regulatory and legal obligations:

Transaction Monitoring: We monitor your investing account activity and transactions to ensure compliance with financial regulations, detect suspicious activity, and fulfill our obligations under anti- money laundering and counter-terrorism financing laws. This monitoring is conducted on an ongoing basis and may include analysis of transaction patterns, volumes, and other relevant factors.

Reporting Suspicious Activity: If we detect or suspect fraudulent, illegal, or suspicious activity in connection with your investing account or transactions, we may report such activity to relevant regulatory authorities, law enforcement agencies, or financial intelligence units as required or permitted by law. We are legally prohibited from notifying you in advance of or following such reports, and we will not be liable for any disclosure made in good faith pursuant to our legal and regulatory obligations.

5. HOW WE COLLECT YOUR PERSONAL INFORMATION

• You Provide Information to Us. We collect information about you when you open an investing account, use, or apply to use our Advisory Services, interact with our Advisory Services, or otherwise engage or communicate with us.
• Automatically Through Our Advisory Services. We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). For more details on our use of cookies and other automated technologies, please review our Cookie Notice.
• From Business Partners and Service Providers. We obtain personal information and related information from specialized third-party service providers and partners to comply with legal requirements and facilitate Advisory Services:
  • Verification Service Provider: We receive verification results from our identity verification service provider, such as Onfido. This includes confirmation of the successful or unsuccessful verification of your submitted documents and biometric data, reports confirming your PEP status, if you are on any sanctions list, and any other relevant information.
  • Partner Clearing Broker: We may obtain personal information and transactional data from our partner clearing broker, such as Alpaca, as necessary for the settlement and clearance of your trades, regulatory reporting, and account reconciliation.
• Other Sources. We may also collect personal information using any other methods or sources detailed in our Privacy Policy.

6. HOW WE USE YOUR PERSONAL INFORMATION

We use information that we collect about you or that you provide to us, including any personal information, to:

• Maintain and provide the Advisory Services, including processing account applications, authenticating your identity, repairing our Advisory Services, supporting, processing and recording transactional information, and handle billing and account management.
• Send transactional or relationship information, including confirmations, invoices, technical notices, customer support responses, software updates, security alerts, support and administrative messages, and information about your transactions.
• Communicate with you about offers and other information we think you will be interested in, such as newsletters, product announcements, partner offerings, surveys, contests or sweepstakes, events or announcements, and personalized advertising.
• Personalize our Advisory Services, such as by suggesting content or customizing content or ads we show you.
• Monitor and improve our Advisory Services, including by analyzing your information and creating aggregated data derived from your information; to develop, maintain, analyze, improve, optimize, measure, and report on our Advisory Services and their features and how users interact with them. Our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing them with third parties for model training.
• Promote our Advisory Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Advisory Services.
• Notify you when Advisory Services updates are available and about changes to any products or services we offer or provide through them.
• Help protect the safety and security of our Advisory Services, businesses, and users, such as investigating and helping prevent fraud or other unlawful activity.
• Protect or exercise our legal rights or defend against legal claims, including enforcing and carrying out contracts and agreements; and
• Any other lawful purpose for which we obtain your consent.

7. WHO WE DISCLOSE YOUR INFORMATION TO

We are committed to maintaining your trust, and we want you to understand when and with whom we disclose information about you. We disclose information about you in the instances described below.

• Authorized vendors: We disclose information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing services, tax and accounting services, contest fulfillment, web hosting, and analytics services, and other third parties we use to support our organization. Third parties are granted access only to the minimum personal data necessary to perform their specific functions, and they are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. For example, we use an identification verification service provider, Onfido, to help determine whether a selfie you take matches the photo in your government-issued identification. With your consent, we may also record your voice and send this data to our vendor to authenticate you and to help prevent fraud. The information collected from your photo and your voice by our vendors for these purposes may include biometric data. Data collected for the purpose of opting in to text messaging services will not be sold or shared with third parties for their marketing or promotional purposes.
• Companies in which you hold securities: Musaffa may provide your name, address, email address, and securities positions to requesting companies in which you hold securities.
• Partner broker-dealer and financial institutions: We disclose information about you to our partner clearing broker-dealer and to payment processors and financial institutions as necessary to process transactions, including deposits, withdrawals, fund transfers, and other payment-related activities on your investing account.
• Others: We may also disclose your personal data to other persons as detailed in “Who do we share personal information with” section of our Privacy Policy.

8. THIRD-PARTY TRACKING AND ONLINE ADVERTISING

We use third-party advertising and analytics services to better understand your online activity and serve you targeted advertisements. These services collect information about your use of our Advisory Services and other websites and online services over time through cookies, device identifiers, or other tracking technologies.

We may share certain personal information (such as email address, device identifiers, and account status) with third-party marketing service providers and advertising platforms to help us market our Advisory Services, including for ad attribution, conversion tracking, and improving our ad targeting. These service providers process your information on our behalf and for our benefit only-not for their own independent marketing purposes. This sharing is necessary for us to operate and promote our Advisory Services effectively.

For further details regarding the use of these technologies, including cookie management options, please review our Cookie Notice.

9. YOUR RIGHTS AND CHOICES ABOUT YOUR INFORMATION

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

• Cookie controls: Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Advisory Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.
• Promotions by the Company. If you do not wish to receive marketing communications from us, you can opt out by logging into your account and adjusting your account settings and preferences or sending us an email stating your request to privacy@musaffa.com. Please note that even if you opt out of marketing communications, (1) you will continue to receive essential service- related communications necessary for the operation of your investing account, including transactional confirmations, account statements, security alerts, legal notices, and other communications required to provide the Advisory Services or comply with legal and regulatory obligations, and (2) we may continue to share your information with marketing service providers and advertising platforms as described in Section 8 of this Privacy Notice for purposes of marketing our Advisory Services, even if you opt out of receiving marketing messages directly from us.
• Location Data. You can choose whether or not to allow the Advisory Services to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some Advisory Services features may become inaccessible or not function properly.

Please note that if you are a new customer, we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share our information as described in this notice. However, you can contact us at privacy@musaffa.com at any time to limit our sharing.

Additional rights and choices you have regarding your personal information are outlined in our Privacy Policy and apply to your use of the Advisory Services.

10. YOUR STATE PRIVACY RIGHTS

Depending on your state of residency, you may have certain rights related to your personal information, including:

• Access and Data Portability. You may confirm whether we process your personal information and access a copy of the personal information we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal information that we maintain, taking into account the information's nature and processing purpose.
• Deletion. You may request that we delete personal information about you that we maintain, subject to certain exceptions under applicable law. These rights remain available to you even after your investing account has been closed, and you may continue to exercise them with respect to any personal information we retain.
• Opt-Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal information for these purposes.

The provisions of our Privacy Policy concerning your state privacy rights are applicable to your use of our Advisory Services.

11. HOW WE PROTECT YOUR PERSONAL INFORMATION

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal information transmitted to, through, using, or in connection with the Advisory Services. In particular, email, texts, and chats sent to or from the Advisory Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal information is at your own risk.

The safety and security of your information also depend on you. You are responsible for taking steps to protect your personal information against unauthorized use, disclosure, and access.

In the event of a data breach that affects your personal or financial information, we will notify you and provide information about the breach, the data affected, and steps you can take to protect yourself. We will also notify relevant regulatory authorities as required by applicable law.

12. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

Pursuant to applicable laws and regulations, we keep the categories of personal information described in this Privacy Notice for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Advisory Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. In accordance with securities and financial services regulations, certain data related to your investing account, transactions, and identity verification must be retained for specific periods. For example, we retain account opening documentation, transaction records, and communications for periods required by applicable securities laws and regulations, including but not limited to requirements under SEC regulations, FINRA rules, and anti-money laundering laws, which may require retention for periods ranging from three to seven years or longer depending on the record type and applicable jurisdiction. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal information will be deleted, destroyed, or deidentified.

13. HOW TO CONTACT US

To exercise your rights or ask questions, or comment about this Privacy Notice or our privacy practices, contact us at privacy@musaffa.com.

14. ACCOUNT CLOSURE AND DATA RETENTION AFTER TERMINATION

You may request to close your investing account at any time by contacting our customer service team at support@musaffa.com or through your account settings in the Platform. Upon receipt of your account closure request, we will process your request in accordance with applicable laws and regulations. Account closure may require settlement of any outstanding transactions, payment of fees or balances owed, and completion of other administrative procedures necessary to wind down your account. We will confirm closure of your account in writing. Following account closure, we will retain your personal information and trading records in accordance with the retention periods described above and as required by applicable laws and regulations.

Cookie Notice

About Us

Our website musaffa.com ("Website"), any associated Musaffa mobile applications, present or future, (“Application”), are operated by, and the services available on Website and Application from time to time (“Services”) are provided by, Musaffa LLC and its Affiliates (“Musaffa”, “we”, “our” or “us”).

What is the Scope of this Cookie Notice?

This Cookie Notice supplements our Privacy Policy and specifically explains the types of cookies and other tracking technologies that we may place on your device, either when you are visiting our Website or Application or if you are using our Services through the Website or Application. Unless otherwise defined in this Cookie Notice, the terms used in this Cookie Notice have the same meanings as in our Privacy Policy and our Terms of Use.

Can our Cookie Notice change?

This notice may change from time to time. Changes to this Notice are effective when they are posted on this page and your continued engagement with our Services after any such revisions indicates that you accept and consent to them, so please check our Cookie Notice periodically for updates.

What are Cookies?

A cookie is a small amount of information that is downloaded to your computer or device when you visit certain websites. A cookie allows applications to distinguish your device from other users’ devices. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you do not have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it is their first time visiting or if they are a frequent visitor. Read more about how we use the data collected through these technologies, in our Privacy Policy.

Do Cookies hold your Personal Information?

Generally, cookies do not contain personal information unless you have already given this information to us through our Website, our Application, or Services.

What are our Main Principles and Purposes in using Cookies?

We always respect our customers’ privacy and personal information, and we take this matter very seriously. We have worked very hard to earn our customers’ trust and keeping it is our top priority. Our Website or Application uses cookies or other automatic data collection technologies to distinguish you from other Website or Application users. This helps us deliver better and more personalized Services when you browse our Website or Application. It also allows us to improve our Website and Application by enabling us to:

• Estimate our audience size and usage patterns.
• Store your preferences so we may customize our Website or Application according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Service.
• Ensure a quality, consistent, and efficient experience for our users.
• Analyze your usage of our Services and interactions with content (including emails).

What are the Categories of Cookies we use:

• Essential Cookies are required so our Website and Application work in the way you expect. Examples of these types of cookies are login cookies which keep you logged in and move around the Website and Application and use their features.
• Analytics Cookies which are used for internal analytics and include cookies from providers like Google Analytics.
• Functional Cookies for customizing content and for helping to provide you with a better experience while using the Website or Applications.
• Marketing Cookies which are used for advertising to you of our Services.
• Third-Party tracking technologies which may use cookies to collect information about you when you use our Website or Application.

What Do We Do with the Cookies in Each Category?

Third Party Analytics Tracking Technology:

What Are Your Options to Manage Cookies?

There are a few ways you can choose how cookies are used on our Website or Application.

You may refuse to accept browser cookies by activating the appropriate setting on your browser or mobile device. However, if you select this setting, certain parts of our Website or Application may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

There are also online tools such as Digital Advertising Alliance's Browser Check and European Interactive Digital Advertising Alliance's Your Online Choices site which allow you to choose how cookies are used throughout the web based on the device and browser you are using.

Your browser probably gives you cookie choices. For example, most browsers let you block “third-party cookies,” which are cookies from sites other than the one you are visiting. Those options vary from browser to browser, so check your browser settings for more info. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

If you do not want these cookies on your device, you can change your cookie settings at any time through your web browser settings. We have supplied links to several of the more popular browsers for procedures on how to view and disable cookies.

• Google Chrome browser
• Microsoft Internet Explorer browser
• Mozilla Firefox browser
• Apple Safari browser
• Opera web browse

You may opt-out of Google Analytics including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager. To provide you with more choice on how your data is collected you should install the “Google Analytics Opt-out Browser Add-on” provided by Google and available from https://tools.google.com/dlpage/gaoptout.

Finally, your mobile device has settings that allow you to control whether ad partners can use information about your use of mobile applications to show ads to you. On iOS devices, this setting is called “Limit Ad Tracking” and on Android devices, this setting is called “Opt out of Ads Personalization.”

Many of the third-party advertising and other tracking services listed above offer you the opportunity to opt out of their tracking systems. You can read more about the information they collect and how to opt out through the privacy policy links listed above.

How can you contact us?

If you have any questions about this Cookie Notice or any other queries or complaints, we are here to help – please contact us via the following email: privacy@musaffa.com