The Folder — Privacy Policy

At The Folder, we help estate planning law firms and the families they serve keep their most important documents organized, understandable, and up to date. Because the information we handle is among the most personal and sensitive a person can have — wills, trusts, healthcare directives, financial details, and family plans — we take privacy seriously. This Privacy Policy explains, in plain language, what information we collect, how we use it, who we share it with, and the choices and rights you have.

Please read this Policy carefully. By using The Folder, you agree to the practices described here. If you do not agree, please do not use The Folder.

1. Who We Are and Who This Policy Covers

The Folder is a software platform operated by The Folder Inc. ("The Folder," "we," "us," or "our"). The Folder is offered through estate planning law firms and is also used directly by individuals and their families.

This Policy applies to two main groups of users:

• Firms: Estate planning law firms and their staff who use The Folder to organize documents, manage client relationships, and serve their clients.
• Individuals and Families: Clients of those firms — and, in some cases, people who sign up directly — who use The Folder to store, review, understand, and share their estate planning documents. We call the person who owns an account a "Primary User," and anyone they invite to access their account an "Authorized User."

This Policy applies to users in the United States. The Folder is not currently offered outside the United States.

2. Our Role — Working With Firms and Families

Because The Folder serves both firms and individuals, our legal role depends on how your information came to be in The Folder. This matters because it affects who is responsible for decisions about your information.

When a firm uses The Folder to serve its clients

When a law firm enrolls its clients and places documents or information into The Folder on their behalf, the firm directs how that information is used. In that situation, the firm is responsible for its relationship with its clients, and The Folder acts as a service provider that processes information on the firm's instructions. Our handling of that information is also governed by our agreement with the firm. If you are a client of a firm and you want to access, correct, or delete information your firm placed in The Folder, we may direct your request to your firm, or work together with your firm to handle it, because the firm controls that information and may have its own legal and professional obligations to retain client records.

When you use The Folder directly

When you sign up for and use The Folder on your own — rather than being enrolled by a firm — we are responsible for the information you provide, and we handle your privacy rights requests directly.

In both situations, the protections in this Policy apply to your information.

3. Information We Collect

We collect the following categories of information:

Firm account information

When firms and their staff use The Folder, we collect the firm's name and contact details, the names, titles, email addresses, and login credentials of firm personnel, billing information, and records of how the firm uses the platform.

Individual and family account information

When a Primary User account is created — by a firm or directly — we collect the person's name, email address, mailing address, phone number, and, where needed to confirm identity, date of birth or government-issued identification. We also collect login credentials and information about the people a Primary User chooses to invite.

Authorized User information

When a Primary User invites someone to access their account, we collect that person's name, email address, and the information needed to verify them and set up their access. A Primary User may invite anyone they choose. Authorized Users may include, for example, a spouse or partner, adult children or other family members, a trustee or successor trustee, an executor, an agent under a power of attorney, a healthcare agent, a beneficiary, an accountant, a financial or wealth advisor, an insurance advisor, or an attorney. This list is just to give examples — the Primary User decides who has access.

Your documents and estate planning information (sensitive)

The heart of The Folder is your documents. We store and process the contents of the estate planning documents and information placed into The Folder, which may include wills and trusts, powers of attorney, healthcare directives and living wills, beneficiary designations, financial account and asset details, property and insurance records, and other documents that reflect your estate and legacy plans. We treat this information ("Document Content") as sensitive, and we protect it accordingly. We use it only to provide the services you and your firm have asked for — secure storage, plain-language summaries, and sharing with the people you authorize. We never sell it, and we never use it for advertising.

Reviews and life updates

The Folder can help you keep your estate planning information current. From time to time, you may choose to complete a review or tell us about a life change — such as a marriage or divorce, a birth or death in the family, the sale of a business, a change in your assets, or a change to a beneficiary. Completing reviews and providing updates is entirely optional. Your firm may periodically invite you to review or update your information to help keep your plan current, but you are never required to do so. We refer to this information as "Update Data." You decide whether, and what, to share with your firm — Section 7 explains how this works.

Support information

When you contact us for help, we collect your name, contact details, account information, and a description of your question so we can assist you.

Information collected automatically

When you use The Folder, we automatically collect some technical information, such as your IP address and the dates and times you visit, using cookies and similar technologies. Section 9 explains more.

Employee and business-contact information

We collect information about job applicants, employees, and the representatives of firms and other partners, for employment and business purposes.

4. Sensitive Information and Your Consent

Much of what The Folder holds is "sensitive" information under privacy laws — including financial details, health-related information in healthcare directives, and other personal details in your documents. By creating an account and placing your information into The Folder, you give us your consent to collect and use this sensitive information for the purposes described in this Policy. We use sensitive information only to provide The Folder's services and to share with your firm or attorney when you choose to, as described in Section 7. We do not use it for advertising or to build marketing profiles, and we do not sell it. You can withdraw your consent by closing your account, though doing so will end your ability to use The Folder.

5. Consumer Health Data

Some of the documents in The Folder — such as healthcare directives and living wills — may contain information about your health or healthcare wishes. Certain state laws treat this as "consumer health data" and give it special protection. We collect and use this information only to provide the services you have requested through The Folder, and we obtain your consent to do so when you enroll and place these documents in The Folder. We do not sell consumer health data, and we share it only as described in this Policy. The Folder is not a healthcare provider and is not subject to HIPAA; the protections in this Policy apply instead.

6. How We Use Information

We use the information we collect to:

• Provide, maintain, and improve The Folder and its features;
• Create plain-language summaries of your documents and Annual Reviews;
• Help you keep your estate planning information current and, when you choose, share updates with your firm or attorney, as described in Section 7;
• Verify identity and enable the access you and your firm set up;
• Provide customer support and respond to your requests;
• Process payments and administer accounts;
• Keep The Folder secure and detect and prevent fraud or misuse;
• Send service messages and, with your consent, educational or marketing content about estate planning; and
• Comply with our legal obligations.

We do not use your Document Content or other sensitive information for advertising or to build profiles about you.

7. Sharing Information With Your Firm

The Folder is built around your control. You decide whether to share information with your firm or attorney, and you can change your mind at any time. We do not share your reviews or updates with a firm unless you choose to share them.

Your firm or attorney

The firm or attorney connected to your account is the one you can choose to share information with. This may be the firm that enrolled you, or an attorney you designate. You can update or remove this connection in your account settings.

Reviews and updates are optional

Your firm may periodically ask you to review or update your information to help keep your plan current. These requests are never mandatory — you decide whether to complete them, and there is no penalty for choosing not to.

You control what is shared

When you add or update information in The Folder — including changes such as a new beneficiary or a change in marital status — you decide whether to share it with your firm. We do not make all of your updates available to your firm. You can always turn off automatic sharing of any update, and you can always choose to share specific information when you want to. In short, you stay in control of what your firm sees, and you can opt out of any automatic sharing at any time.

Your information is yours

The information you place into The Folder belongs to you. If you change firms, or your relationship with a firm ends, your information remains yours to keep private. We will not hand your information to a former firm, and you decide whether to share any of it with a new firm. When you do choose to share information with your firm, we share only what you have chosen to share, and only with that firm — never with any other advisor, family member, or third party, and we never sell it.

8. How We Share Information

We share information only as described below. We do not sell your personal information, and we do not share it for targeted or cross-context behavioral advertising.

• Service providers: Companies that help us run The Folder — such as hosting, data storage, billing, payment processing, identity verification, and analytics — may process information on our behalf. They are bound by contracts that limit them to working for us and prohibit them from selling or reusing your information.
• Artificial intelligence providers: We use third-party AI providers to power features like document summaries. They act only as our service providers under strict contracts. Section 10 explains this in detail.
• Your firm or attorney — only when you choose: We share your updates or review results with your firm only when you choose to share them. You stay in control, and you can opt out of any automatic sharing at any time, as described in Section 7.
• People you authorize: We make your information available to the Authorized Users you invite, as you configure. Section 11 explains your responsibility for managing this access.
• Affiliates: We may share information with companies under common ownership with us, for the purposes in this Policy.
• Legal and safety: We may disclose information to comply with the law, respond to lawful requests or legal process, enforce our agreements, or protect the rights, property, or safety of our users, the public, or The Folder.
• Business transfers: If The Folder is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will provide notice as required by law.

9. How We Use Artificial Intelligence

Artificial intelligence is built into The Folder. We use third-party AI technology to generate plain-language summaries of documents and Annual Reviews and to help identify changes that may affect a plan. Because AI is core to how The Folder works, it applies to all users; there is no separate per-user opt-out. By using The Folder, you consent to AI-assisted processing of your information as described here. The following protections apply:

• What AI works with: AI processes Document Content and Update Data to create summaries and identify potential plan changes.
• Data minimization: We limit what is shared with AI providers to what is needed. Where reasonably possible, we take steps to mask or remove highly sensitive identifiers — such as Social Security numbers and financial account numbers — before content is processed by AI.
• Strict provider contracts: Our AI providers act only as our service providers. Their contracts prohibit them from using your information to train or improve their AI models, from selling or sharing it, and from keeping it longer than needed to perform the service.
• No training on your data: We do not allow AI providers to use your information to train, fine-tune, or improve their models.
• Human oversight: AI summaries are informational tools, not legal advice. No legal decision — including whether your plan should change — is made by AI alone. Those decisions are always made by you and your attorney.

A current list of our AI providers is available on request using the contact details in Section 17.

10. Access You Give to Others, and Their Conduct

The Folder lets you decide who can see your information. With that control comes responsibility, which this section explains.

• You control access. You choose who to invite as an Authorized User, and you can change or remove their access at any time in your account. We carry out the access settings you choose; we do not independently judge whether the people you invite are appropriate or trustworthy.
• You are responsible for keeping access current. You are responsible for updating access when your circumstances change — for example, after a divorce or separation, a death, a change of advisors, or the removal of a trustee or executor. We do not automatically know about these changes, and we will not change or remove someone's access unless you tell us to through The Folder.
• We are not responsible for what Authorized Users do. Once you have given someone access, we are not responsible for how they use, copy, share, or store the information they can see. This includes situations where you forgot to remove someone's access after a relationship changed, or where someone uses information in a way you did not intend or that is contrary to your interests. The Folder provides the tools for access; it is not part of the relationships between you and the people you invite.
• Please review access regularly. We encourage you to review who has access to your account from time to time, especially after a major life event. We may remind you to do this, but those reminders do not replace your responsibility to manage access yourself.
• Authorized Users' responsibilities. Anyone who accepts an invitation to access an account agrees that their access can be removed at any time, that the information is confidential, that they will not use it against the account owner's interests, and that they are responsible for their own actions with the information.

The Folder is not a party to and will not mediate disputes between account owners and the people they have invited, except as required by law.

11. Cookies, Tracking, and Your Signals

We use cookies and similar technologies to keep you logged in, remember your preferences, keep The Folder secure, and understand how the platform is used so we can improve it. You can control cookies through your browser settings, including blocking or deleting them, though some features may not work without them.

Global Privacy Control. Because we do not sell your personal information or share it for targeted advertising, there is no advertising activity for you to opt out of. Where applicable, we will treat a recognized browser privacy signal, such as Global Privacy Control (GPC), as a valid request to opt out. Our website does not respond to older "Do Not Track" signals, which are not standardized.

12. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal information:

• Know and access — to learn what personal information we hold about you and to get a copy of it;
• Correct — to fix inaccurate personal information;
• Delete — to ask us to delete your personal information, subject to legal exceptions and, where a firm controls the information, the firm's record-keeping obligations;
• Portability — to receive your information in a portable format, which for Primary Users includes exporting the documents in your account;
• Limit sensitive information — to limit our use of your sensitive information to what is needed to provide the service;
• Opt out — to opt out of any sale or sharing of personal information for targeted advertising or of certain profiling; we do not engage in these activities; and
• Non-discrimination — to exercise your rights without being treated differently or receiving a lesser service.

13. How to Exercise Your Rights

Making a request. You can exercise your rights by contacting us using the details in Section 17. If your information was placed in The Folder by your law firm, we may direct your request to your firm or work with them to respond, as explained in Section 2.

Verifying your identity. Because The Folder holds highly sensitive documents, protecting against improper access is essential. Before we act on a request — especially a request to access, export, or delete documents — we will take steps to verify your identity, and we may ask for additional information to confirm who you are. If we cannot verify your identity, we may be unable to fulfill your request. This protects you from someone else gaining access to your information.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We may require the agent to show proof of authorization and may ask you to verify your identity directly.

Our response. We will respond to your request within the time required by applicable law — generally within 45 days, with the ability to extend when reasonably necessary, in which case we will let you know.

Appeals. If we deny your request, you may appeal our decision by contacting us using the details in Section 17 and telling us you wish to appeal. We will review your appeal and respond within the time required by law. If we deny your appeal and your state provides one, you may contact your state attorney general to file a complaint.

14. Your State Privacy Rights

Many U.S. states have comprehensive privacy laws that provide the rights described in Section 12, along with the right to appeal described in Section 13. These states include California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and Washington. Nevada also provides certain privacy rights, including the right to tell us not to sell your covered information.

The specific rights available, and the situations in which they apply, vary from state to state. Some rights may not apply to information that your law firm controls, or where an exception under the applicable law applies. Regardless of the state you live in, you may exercise any rights available to you using the process in Section 13, and we will honor the rights that apply to you under your state's law.

California

If you are a California resident, you have the rights described above under the California Consumer Privacy Act, as amended. We collect the categories of information described in Section 3, including sensitive personal information such as financial and health-related details contained in your documents. We use and disclose this information only for the purposes described in this Policy. We do not sell or share your personal information, and we do not use sensitive information for advertising or profiling. California residents may exercise their rights, including the right to limit the use of sensitive personal information, using the process in Section 13, and will not be discriminated against for doing so.

Nevada and Washington — health data

If you live in Nevada or Washington, you may have additional rights regarding consumer health data under those states' health-data laws, including the right to confirm, access, delete, and withdraw consent for the processing of that data. You can exercise these rights using the process in Section 13.

15. Children's Information

The Folder is not intended for children under 13, and we do not knowingly collect personal information directly from children under 13. If you believe a child under 13 has provided us information, please contact us and we will delete it. Estate planning documents sometimes name minor children — for example, as beneficiaries. Where your documents include information about minors, we treat it as sensitive and use it only to provide The Folder's services. Please do not include information about minors beyond what is needed for estate planning purposes.

16. How We Protect Information

We use a combination of technical, physical, and organizational safeguards to protect your information, including:

• Encryption of information in transit and encryption of your documents and sensitive information at rest;
• Access controls that limit access to information to people who need it;
• Multi-factor authentication for account access;
• Regular security reviews and testing; and
• Security reviews of our service providers, including our AI providers.

We do not store full payment card numbers; payments are handled by a secure, industry-compliant payment processor. No system can be guaranteed to be perfectly secure, so we cannot promise absolute security, but we work hard to protect your information. If a security incident affects your personal information, we will notify you as required by law.

17. How Long We Keep Information

We keep information for as long as needed to provide The Folder's services and to meet our legal, accounting, and record-keeping obligations. In general:

• Your documents are kept while your account is active and for a reasonable period afterward to allow recovery; when an account ends, documents may be exported during a defined window and are then securely deleted.
• Account information is kept while your account is active and for any period required by law afterward.
• Reviews and life updates are kept while your account is active and as needed to maintain a history of plan changes.
• Technical and support information is kept for a limited period for analytics, quality, and legal purposes.

When you ask us to delete your information and we are able to do so, we also instruct our service providers, including our AI providers, to delete it.

18. Links to Other Websites

The Folder may contain links to other websites or services we do not operate. We are not responsible for their privacy practices, and we encourage you to read their privacy policies.

19. Changes to This Policy

We may update this Policy from time to time. When we make changes, we will post the updated Policy here and update the "Last Updated" date above. If we make a material change — such as a change to how we use or share your documents or sensitive information, how we use AI, or how information is shared with your firm — we will give you advance notice by email or through The Folder at least 30 days before the change takes effect, where required. If you do not agree with a change, you may close your account.

20. Contact Us

If you have questions about this Policy or your information, or if you wish to exercise your privacy rights, please contact us:

The Folder Inc. — Helping families keep what matters organized, understood, and up to date.