Vzable (“Vzable”, “us”, “our”, and “we”) a d/b/a of Pathwise LLC is committed to maintaining robust privacy protections for visitors of vzable.com (“Site”).  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use, and safeguard the information you provide to us and to assist you in making informed decisions when using our Site.  

By using or accessing our Site, you acknowledge that you have read and understood this Privacy Policy and Terms of Use (found here: located at vzable.com/terms-of-use), Your continued use of the Site signifies your consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. Capitalized terms in this policy have the same meaning given to them in our Terms of Use, unless otherwise defined in this policy.

Children’s Online Privacy Protection Act

We do not intentionally gather Personal Information from visitors who are under the age of 13 without parental consent. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 without parental consent, please contact us at info@vzable.com.

Types of Data We Collect

We collect “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

Information You Provide to Us

• We may collect Personal Information from you, such as your name and e-mail address when you complete a contact form on our Site.
• If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
• When you post content on a social media site where we have a page or presence the information contained in your posting may be republished on our Site and other users may be able to see them.

Information Collected via Technology

• In an effort to improve the quality of the Site, we track information provided to us by your browser or by our software application when you view the Site, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Site, the time and date of access, and other information that does not personally identify you.  We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our Site, both on an individual and aggregate basis. We may also ask advertisers or other partners to serve ads to your devices, which may use cookies or similar technology.
• We may also use third-party analytics platforms such as Google Analytics or Google Ads to collect information about how you use and interact with our Site. Such third-party analytics services may use cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and which site referred you to the Site. This helps us provide a better user experience, improve usability, analyze website traffic and performance, measure conversions, and improve marketing campaigns.
• We may utilize the Facebook Pixel, a web analytics and marketing tool provided by Facebook Inc. (“Facebook”). This tool enables us to understand and deliver ads and make them more relevant to you. The Facebook Pixel collects data that helps us track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to people who have already taken some kind of action on our Site. When you visit our Site, the Pixel may collect information about your interaction with our Site, such as the pages you visit, the products or services you viewed, and whether you completed any actions, such as making a purchase. This data is collected through the use of cookies. The collected information may be shared with Facebook and used in accordance with Facebook’s Data Use Policy. Facebook uses this data to provide us with insights about the effectiveness of our ads and to deliver targeted advertising based on your online activity. We do not share any of your personally identifiable information with Facebook through the Pixel. You have the right to opt out of the collection and use of your information for targeted advertising. For more information on how to manage and delete cookies, please refer to your browser’s help material. Additionally, you may control your ad preferences and opt out of targeted advertising from Facebook in your Facebook account settings.

Use of Your Personal Information

We may process your Personal Information based on one or more of the following legal bases:

Your Consent: You may give us permission to process specific data to enhance your experience on the Site.

Contractual Obligations: We may process personal data to fulfill our contractual obligations to you.

Legitimate Interests: We may process personal data to improve the Site more effectively, and secure our Site, as long as these interests do not override your rights.

Legal Obligations: We may be required to process certain personal data to comply with applicable laws and regulations.

Use of Non-Personal Information

In general, we use Non-Personal Information to help us improve the Site and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

Disclosure of Your Personal Information

Our company does not sell your personal information. We do, however, have relationships with third parties to provide our Site to you in which your personal information may be shared. We disclose your Personal Information as described below and as described elsewhere in this Privacy Policy.

Third-Party Service Providers. We may share your Personal Information with third-party service providers to facilitate the Services we offer you through our Site. Specifically, these service providers assist us in:

• Hosting and Customer Support: Service providers help host our Site, manage our servers, and provide customer support to address your inquiries.

• Quality Assurance and Performance Monitoring: We conduct quality assurance testing and monitor the Site’s performance to ensure it operates as expected.

• Marketing and Data Analysis: Third parties may assist in marketing efforts, conducting data analysis to understand user engagement, and improving the Site.

• Technical Support and Troubleshooting: Our service providers offer technical support and assist in troubleshooting issues on the Site.

• Additional Services: We work with third parties to provide other services aimed at enhancing the user experience on our Site.

These service providers are contractually obligated to protect the confidentiality and security of your Personal Information and to use it only as directed by us.

Affiliates and Business Partners. We may share your Personal Information with our affiliates and business partners to perform functions and provide services on our behalf, such as marketing initiatives or improving the Site’s functionality. These partners are required to use your Personal Information only for the purposes outlined by us and in compliance with applicable laws.

Corporate Transactions. In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your Personal Information may be transferred to a successor entity as part of the transaction. We will take reasonable steps to ensure that your Personal Information remains secure and is handled in accordance with this Privacy Policy.

Other Disclosures. Vzable is committed to protecting your privacy and the confidentiality of your personal information. We will not disclose your Personal Information to any third parties except in the following limited circumstances, and only to the extent required or permitted by law:

• Legal Obligations: We may disclose Personal Information if required to comply with applicable laws, regulations, or legal processes (such as subpoenas, court orders, or other legal requests). In such cases, we will take reasonable measures to limit the scope of the information disclosed and, where possible, will notify you in advance.

• Protection and Safety: We may disclose Personal Information to protect the rights, property, or safety of Vzable, our users, or others. This includes actions to detect, prevent, or otherwise address fraud, security, or technical issues, and to enforce our Terms of Use.

• Responding to Government Requests: In the rare event we receive a request from a public authority, including for law enforcement or national security purposes, we will carefully evaluate the legality and necessity of the request. Where permitted, Vzable will strive to notify you and to seek the minimum disclosure possible in response to such requests. Your personal information is treated with the utmost sensitivity, and we will take all reasonable steps to protect it from unwarranted disclosure.

Commitment to Transparency. Vzable believes in transparency regarding our handling of personal information. Should we receive requests from public authorities or other third parties for user data, we will evaluate each request carefully. We are committed to protecting your privacy and will take appropriate measures to ensure that any disclosures are in line with our privacy principles and, where possible, will notify you of such disclosures.

Data Security During Disclosures. When disclosing your Personal Information to third parties as described above, we take steps to protect the confidentiality and security of your data. We strive to use industry-standard safeguards and require third parties to implement similar protections, ensuring your information remains secure throughout any processing.

Links to Third Party Websites

As part of the Site, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Site. To the extent that you access or use the Site through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

Your Rights Regarding the Use of Your Personal Information

You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by unsubscribing, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the Personal Information that you may have provided through your use of the Site. If you wish to access or amend any other Personal Information we hold about you, or to request that we delete any information about you that we have obtained from our Site, you may contact us at: info@vzable.com with the email subject as “Personal Information Query.”

At your request, we will have any reference to you deleted or blocked in our database.

You may decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of the Site.

At any time, you may object to the processing of your Personal Information, on legitimate grounds, except if otherwise permitted by applicable law.

Security of Your Personal Information

We implement security measures designed to protect your information from unauthorized access and potential security breaches by implementing certain technological security measures. Vzable protects User data by using industry-accepted administrative, technical, and physical safeguards designed to secure information against unauthorized access, disclosure, alteration, or destruction. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee its absolute security. Vzable maintains a data breach response plan. In the event of a security incident involving your data, Vzable will provide legally required notifications to affected users and, where applicable, to regulators and individuals, in accordance with applicable law. By using our Site, you acknowledge that you understand and agree to assume these risks.

How Long We Retain Your Data

We will keep hold of your data for no longer than necessary. The length of time we retain it will depend on any legal obligations we have (such as tax recording purposes), the nature of any contracts we have in place with you, the existence of your consent or our legitimate interests as a business.

Do Not Track Signals

Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser. Vzable adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

Notices

Notice to California Residents. The California Consumer Privacy Act (“CCPA”) provides California consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA: (1) disclose certain information to you about their collection and use of your Personal Information over the past 12 months; (2) delete Personal Information collected from you, subject to certain exceptions; and (3) ask whether the business sells Personal Information and right to opt-out of that sale. To request the above information, you may contact us at: info@vzable.com with the email subject as California Disclosure Information.

California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code. As required by the California Act, this Privacy Policy identifies the categories of personally identifiable information that we collect through our Site about individual consumers who use or visit our Site and the categories of third-party persons or entities with whom such personally identifiable information may be shared.

Notices to International Users. The Site is hosted in the United States. If you are a User accessing the Site (or providing information that is hosted on or routed through the Site) from the European Union (“EU”), Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please note that you are transferring your personal data to the United States which does not have the same data protection laws as the EU and other regions, and by providing your personal data you permit the use of your personal data for the uses identified above in accordance with the Privacy Policy.

Changes to This Privacy Policy

We reserve the right to change this policy and our Terms of Use at any time. We will notify you of significant changes to our Privacy Policy b by placing a prominent notice on our Site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

Contact Information

If you have any questions regarding this Privacy Policy or the practices of the Site please contact us by sending an email to info@vzable.com.

Last Updated: This Privacy Policy was last updated on September 22, 2025.