Privacy Policy

1. Introduction

Prosperity Rx is a digital platform operated by Freedom Family Investments ("FFI", "we", "our", or "us"), including its affiliate Freedom Family Academy ("FFA"). This Privacy Policy describes how we collect, use, store, and protect your personal information when you use the Prosperity Rx platform, including the website, mobile applications, email communications, and related services (collectively, the "Service").

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information you voluntarily submit through the Service, including:

• Account information: Name, email address, password (stored encrypted), and (optionally) phone number
• Profile information: Professional designation (physician, dentist, etc.), specialty, career stage, geographic location
• Financial information you choose to enter: Income ranges, savings amounts, investment portfolio details, debt information, retirement account balances, financial goals, and any data you input into our calculators (Freedom Number™, Scorecard, Phase Assessment, etc.)
• Investment-related information: Investor accreditation status, investment preferences, and information you submit when scheduling Clarity Calls or expressing interest in investment opportunities. To comply with anti-money laundering laws, we may also require identifying information including your name, address, date of birth, and a government-issued ID prior to any investment participation
• Communications: Content of messages you send to us through email, contact forms, support requests, or any community features
• User-generated content: Notes, highlights, and other content you create within the Service, including documents you upload to the Deal Evaluator

2.2 Information Collected Automatically

When you use the Service, we automatically collect:

• Usage data: Pages visited, features used, time spent, click patterns, navigation paths, search queries
• Device information: Device type, operating system, browser type and version, IP address, screen resolution
• Location information: Approximate geographic location based on IP address (not precise GPS location)
• Cookies and similar technologies: As described in our Cookie Policy

2.3 Information from Third Parties

We may receive information about you from:

• Authentication providers (e.g., Google, Apple) if you use them to sign in
• Payment processors (e.g., Stripe) for any paid features (limited to transaction confirmation; we do not store full payment card details)
• Email service providers (e.g., Resend) for deliverability metrics
• Analytics providers for usage patterns

3. How We Use Your Information

We use the information we collect to:

• Provide the Service: Authenticate you, save your progress, deliver requested content, calculate your Freedom Number™ and other diagnostic results
• Personalize your experience: Recommend chapters, tools, and resources based on your stated goals and usage patterns
• Send communications: Deliver weekly 90-Day Plan emails (if opted in), service announcements, security alerts, and respond to your inquiries
• Connect you with FFI: Facilitate Clarity Call bookings, share information about FFI investment opportunities (only with your express consent), and maintain investor relationship records
• Improve the Service: Analyze usage patterns, fix bugs, develop new features
• Protect the Service: Detect fraud, abuse, security incidents, and violations of our Terms of Use
• Comply with legal obligations: Including anti-money laundering and securities regulations, lawful requests from authorities, and recordkeeping requirements

We do not use your information to:

• Sell or rent your personal information to third parties
• Make automated decisions that legally affect you
• Train artificial intelligence models on your private financial information without your explicit consent

4. How We Share Your Information

We do not sell or rent your personal information. We share your information only as follows:

4.1 With Affiliated Entities

We may share information with FFI affiliated entities, including Freedom Family Academy and other operating companies under common ownership, for purposes consistent with this Privacy Policy and only to provide you services you have requested.

4.2 With Service Providers

We use third-party service providers who help us operate the Service, including:

• Hosting and infrastructure: Supabase, Vercel, or similar
• Payment processing: Stripe (for any paid features)
• Email delivery: Resend
• Analytics: Google Analytics or similar
• Customer support: Tools as deployed
• AI services: Anthropic (Claude) for the Deal Evaluator and similar AI-powered features

These providers are contractually bound to use your information only as necessary to provide their services to us.

4.3 With Investment Professionals (Only With Consent)

If you book a Clarity Call or express interest in an FFI investment opportunity, we will share relevant information you have provided with FFI's investor relations team to facilitate that conversation. You may withdraw this consent at any time.

4.4 For Legal Reasons

We may disclose your information if required by law, court order, regulatory requirement, or government request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or comply with anti-money laundering and securities regulations.

4.5 In Connection with Business Transactions

If FFI is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. You will be notified before your information becomes subject to a different privacy policy.

4.6 We Do Not Sell Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

5. Your Rights and Choices

5.1 Access, Correction, and Deletion

You have the right to:

• Access the personal information we hold about you
• Correct inaccurate information
• Delete your account and associated personal information (subject to certain legal retention requirements described in Section 7)
• Export a copy of your data in a portable format
• Restrict or object to certain types of processing

To exercise these rights, email invest@freedomfamilyinvestments.com or use the settings in your account dashboard.

5.2 Email Preferences

You can opt out of marketing emails at any time using the unsubscribe link in any email or through your account settings. You will continue to receive transactional emails (security alerts, password resets, etc.) as long as you maintain an account.

5.3 Cookies

You can control cookies through your browser settings. See our Cookie Policy for details.

5.4 California Residents (CCPA/CPRA Rights)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• The right to know what categories of personal information we collect, use, disclose, and sell (we do not sell)
• The right to delete personal information we hold about you
• The right to correct inaccurate personal information
• The right to opt out of the sale or sharing of personal information (we do not sell or share for cross-context behavioral advertising)
• The right to limit use of sensitive personal information
• The right to non-discrimination for exercising your rights

To exercise these rights, contact invest@freedomfamilyinvestments.com.

5.5 European Residents (GDPR Rights)

If you are in the European Economic Area, you have additional rights under the General Data Protection Regulation, including the rights of access, rectification, erasure, restriction of processing, data portability, and to object to processing. To exercise these rights, contact invest@freedomfamilyinvestments.com.

Our legal bases for processing your personal information are:

• Consent: When you have given us explicit consent (e.g., marketing emails)
• Contract: When processing is necessary to provide the Service you requested
• Legitimate interests: When we have a legitimate business interest that does not override your rights (e.g., fraud prevention, service improvement)
• Legal obligation: When required by law

6. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your information, including:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of passwords using industry-standard algorithms
• Access controls limiting which employees and contractors can access user data
• Regular security reviews and updates

However, no method of transmission over the internet is completely secure. We cannot guarantee absolute security. If you become aware of a security incident affecting your account, please contact us immediately at invest@freedomfamilyinvestments.com.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. We may retain certain information after account deletion as necessary to:

• Comply with legal, tax, accounting, or regulatory requirements (including SEC and FINRA recordkeeping standards if applicable to investor communications)
• Enforce our Terms of Use
• Resolve disputes
• Protect against fraudulent or harmful activity

Specific retention periods:

• Account information: Retained while your account is active; deleted within 90 days of account closure unless legal retention applies
• Financial information you entered: Retained while your account is active; deleted upon account closure unless legal retention applies
• Investment-related communications: Retained for at least 7 years per FINRA/SEC recordkeeping standards if you became an FFI investor
• Email logs: Retained for 1 year for deliverability and support purposes
• Aggregated/de-identified analytics: May be retained indefinitely

8. Children's Privacy

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will delete that information promptly.

9. International Data Transfers

The Service is hosted and operated in the United States. If you access the Service from outside the United States, your information will be transferred to, stored, and processed in the United States. By using the Service, you consent to this transfer.

For users in the European Economic Area, we rely on Standard Contractual Clauses or other lawful transfer mechanisms to protect your information when transferred internationally.

10. Third-Party Links

The Service may contain links to third-party websites (including the FFI main website at freedomfamilyinvestments.com, scheduling platforms, social media, and partner resources). This Privacy Policy does not apply to those sites. Please be aware that when you leave our website, other websites may have different privacy policies and terms which are beyond our control. We encourage you to review their privacy policies before sharing personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Updating the "Last Updated" date at the top of this policy
• Sending an email notification to your registered email address for material changes
• Displaying a prominent notice within the Service for material changes

Continued use of the Service after changes take effect constitutes acceptance of the updated policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, contact us:

Email: invest@freedomfamilyinvestments.com
Mail: Freedom Family Investments, 251 W. Central Ave. #255, Springboro, OH 45066
Phone: 1-844-877-0888
Hours: Monday–Friday, 9:00 AM – 4:00 PM ET