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Privacy Policy

Last Revised: June 18, 2026 (adapted for akru.com — pending counsel approval)

AKRU Inc. (collectively with its subsidiaries, “AKRU,” “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through our compliance with this Website Privacy Policy (the “Policy”). This Policy should be read in conjunction with our Website Terms of Use, into which this Policy is incorporated by reference.

This Policy describes: the types of information we collect from you or that you may provide when you visit the website available at https://akru.com, as well as any websites and blogs directly owned by AKRU (collectively, our “Website”); and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully. If you do not agree with our policies and practices, please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see “Changes to this Policy” below); your continued use of our Website after we make changes is deemed to be acceptance of those changes.

Scope: Website Visitors vs. Client Services

This Policy governs information collected through the Website, which is informational: it offers no user accounts, investment functionality, or securities transactions. Information that AKRU processes in the course of providing platform, administration, or transfer-agent services to its institutional clients — including investor records maintained in AKRU’s capacity as an SEC-registered transfer agent — is governed by the applicable service agreements and by recordkeeping requirements under applicable securities laws and regulations, not by this Policy. Use of the AKRU investment platform available at akru.co is governed by the platform’s own Privacy Policy and Terms of Use, which contain the vendor-specific disclosures applicable to platform functionality.

Platform Services: Third-Party Providers

AKRU’s products incorporate services from third-party providers. When clients and their authorized end users use the AKRU platform under a service agreement (including white-label deployments), Personal Information is processed by the following categories of providers, each contractually limited to the service it performs for AKRU:

  • Account security (SMS) — Twilio, Inc. delivers one-time passcodes and account-security notifications. Twilio receives only the minimum data necessary to deliver each message (such as your mobile number and message content) and is contractually prohibited from using it for any other purpose. AKRU does not share, sell, lease, or transfer your mobile phone number or SMS opt-in data with any third party for marketing or promotional purposes.
  • Identity verification, KYC and AML — GBG. Performs document-based identity verification for individuals, entity verification (KYB) for organizations, and sanctions and watchlist screening at onboarding and on an ongoing basis. Information processed may include government-issued identification, date of birth, and related verification data.
  • Bank connectivity — Plaid Inc. Gathers your data from financial institutions and facilitates the transfer of your Personal Information to and from financial institutions in connection with platform functionality you elect to use. Your personal and financial information is transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.
  • Payments — Dwolla, Inc. Provides payment functionality through a “Dwolla Platform” account. AKRU collects and shares with Dwolla your personal information including full name, date of birth, social security number, physical address, email address, and financial information; funds held in a Dwolla account are held by Dwolla’s financial institution partners as set out in the Dwolla Terms of Service and Privacy Policy.

Where a client engages AKRU under a white-label deployment, these providers may operate under the client’s brand; the applicable service agreement and end-user terms govern in that case.

What We Collect and How We Collect It

Information You Provide to Us. Personal Information is any information that can be used to individually identify you from a larger group. Through the Website, this may include your first and last name, email address, telephone number, company or organization, professional role, the nature and approximate size of the funds or programs you manage, and comments or messages provided in free text boxes. You may provide us Personal Information when you request information, submit the contact form, request or schedule a meeting, or subscribe to our communications.

Automated Information Collection

In addition to information that you provide to us, we may collect information about you during your visit to our Website using automated tools, such as your internet address (IP address), the pages you have viewed, and the actions you have taken while using the Website. These tools may include:

Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use both of them: session cookies, which do not stay on your device after you close your browser, and persistent cookies, which remain on your device until you delete them or they expire. We use the following categories of cookies on our Website:

  • Strictly Necessary Cookies. Essential in order to enable you to move around the Website and use its features.
  • Performance Cookies. Collect anonymous information on how people use our Website, to help us understand how you arrive at our site and highlight areas where we can improve. The data stored by these cookies never shows personal details from which your individual identity can be established.
  • Functionality Cookies. Remember choices you make, such as preferred language or region, to provide an experience more appropriate to your selections. The information in these cookies may be anonymized, and they cannot track your browsing activity on other websites.
  • Targeting or Advertising Cookies. Collect information about your browsing habits in order to make advertising more relevant to you, limit the number of times you see an advertisement, and help measure the effectiveness of advertising campaigns. These are usually placed by third-party advertising networks.

If you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. By disabling cookies, you may lose access to some Website functionality.

Google Analytics. The Website sends aggregated, non-Personal Information to Google Analytics for the purpose of technical and statistical analysis of the Website’s performance. For more information, please review Google’s policy at policies.google.com/technologies/partner-sites.

Web Beacons. A Web Beacon is an electronic image that can track certain things from your computer and report activity back to a web server. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails, including whether and when you click links. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners. This information is collected in aggregate form and will not be linked to your Personal Information.

Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology accomplished through a redirection system, which allows us to understand how a link is being used. Some of these links may enable us to identify that you have personally clicked a link, and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

Third-Party Websites and Services. We work with service providers of marketing communications technology. These providers may use various data collection methods to improve the performance of the marketing campaigns we contract them to provide, on our Website and on websites where our marketing communications appear.

How We Use Your Information

The information we gather and that you provide is collected to provide you information and services you request, in addition to other purposes, including, but not limited to: responding to your inquiries and meeting requests; providing service and support; providing marketing communications that are effective and optimized for you; keeping you up to date on our products and services; preventing malicious activity and providing you with a secure experience; preventing unwanted messages or content; measuring the performance of our marketing programs; and enforcing our Terms of Use.

How We Share Your Information

We do not sell or lease your information to any third party. We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy — for example, partners that help us process your requests, deliver customer service and support, send email communications, host or analyze the Website, and provide scheduling functionality. These third-party partners are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them.

We may also disclose Personal Information to our auditors, accountants, attorneys, CPAs, and other professional advisors, insurance companies and brokers, and financial institutions, as necessary in the course of the professional services that they render to us. If AKRU is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of AKRU assets, or transition of service to another provider, Personal Information may be disclosed or transferred as part of such a transaction as permitted by applicable law or contract.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances: responding to duly authorized information requests from law enforcement or other governmental authorities; complying with any law, regulation, subpoena, or court order; investigating and helping prevent security threats, fraud, or other malicious activity; enforcing or protecting the rights and properties of AKRU or its subsidiaries; or protecting the rights or personal safety of AKRU’s employees.

Your Choices and Selecting Your Privacy Preferences

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Transactional or service-oriented messages are generally excluded from such preferences, as such messages are required to respond to your requests.

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately, and we maintain processes designed to keep our information in accordance with relevant data governance frameworks and legal requirements. To view or change the Personal Information that you have provided to us through the Website, please contact us directly for assistance.

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen. We do not target the Website to minors and would not expect them to be engaging with our Website or services. If we become aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

Your California Rights

Pursuant to California Civil Code Section § 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent. Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising, and therefore does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

If you are a California consumer, as defined by the California Consumer Privacy Act of 2018, you may be afforded additional rights with respect to your Personal Information, which you may exercise subject to our verification of your identity:

  • Access. You may email us at info@akru.com to request a copy of the Personal Information our Website databases currently contain.
  • Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information by submitting a request via email, explaining which categories of third parties you want to prohibit from receiving your Personal Information.
  • Portability. Upon request and when possible, we can provide you with copies of your Personal Information.
  • Deletion. You may request that your Personal Information be deleted by emailing us; upon receipt, we will confirm receipt and confirm once your Personal Information has been deleted, and where applicable will ensure such changes are shared with trusted third parties.

We do not sell your Personal Information. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information.” If a California resident exercises his or her rights under California law, including the CCPA, we shall not discriminate against that resident by denying our goods or services, charging different prices or rates, providing a different level or quality of goods or services, or taking any other adverse action.

For Website Visitors Outside of the United States

We do not warrant or represent that this Policy or the Website’s use of your Personal Information complies with the laws of any particular jurisdiction. To provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

For Website Visitors in the European Union and United Kingdom

Under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, individuals in the EU and United Kingdom are afforded specific rights with respect to their personal data. For the purposes of this Policy, AKRU operates as a data controller. Any personal data we collect from you is processed in the United States, in the legitimate interest of our business and providing our services to you as the lawful means of such processing. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, and to comply with the law.

The Data Controller is: AKRU Inc., 3825 Edwards Rd., Suite #103, Cincinnati, OH 45209, info@akru.com.

Subject to verification of your identity, you may exercise the following rights by emailing info@akru.com: access; correction or rectification; restriction of processing; objection to processing (including automated processing and profiling); portability; withdrawal of consent (type “WITHDRAW CONSENT” in the subject line of your email); and erasure. When a request cannot be honored, we will advise you accordingly, and you may then choose to exercise any other rights under this Policy. Where applicable, we will ensure changes are shared with trusted third parties. If you wish to raise a complaint about how we have handled your personal data, you may contact us as described below; if you reside in an EU member state, you may also lodge a complaint with the supervisory authority in your country.

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can reach this page from any of our webpages by clicking on the “Privacy Policy” link at the bottom of the screen.

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. Please notify us of any suspected unauthorized use of your information.

How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information:

AKRU Inc.
3825 Edwards Rd., Suite #103
Cincinnati, OH 45209
+1 888 966 AKRU (2578)
info@akru.com