WealthQuest Privacy Policy

This Privacy Policy applies to:Customers who purchase products or services through the WealthQuest platform;IBOs (Independent Business Owners) who enroll to refer Customers and earn compensation; andVisitors to WealthQuest's websites and platform, including prospective Applicants.
‍Products covered. At launch, the WealthQuest platform offers a single product, the WealthVentures membership, sold by WealthQuest, LLC and delivered through the WealthVentures Platform, which is operated by WealthQuest's Affiliated Company, WealthVentures, LLC (Section 2). As additional products are introduced — whether provided by WealthQuest, LLC directly or through an Affiliated Company — this Policy's data practices described below apply to each of them unless a product-specific supplement is issued.
‍How to find your rights. Read this Part I, then read Annex A, which applies to every Customer, IBO, and Visitor covered by this Policy, and then Annex B in addition if you are located in the EU/EEA, United Kingdom, or Switzerland.
‍Document hierarchy. Where this Policy conflicts with a specific data-handling provision of the WealthQuest Independent Business Owner Agreement — General Part, the KYC/AML Statement, or the Policies and Procedures, the more specific document controls for that particular topic (for example, the KYC/AML Statement controls on automated-verification mechanics, Section 6); this Policy controls for all other data-protection matters.
‍Domain. This Policy governs www.wealthquest.com and its subdomains.
‍Language. At this time, WealthQuest's legal documents, including this Policy, are published in English only. WealthQuest intends to make translated versions available in additional languages over time, prioritized by market size and demand, as its international operations develop. Where a translated version is made available, the English-language version remains the authoritative and controlling version in the event of any conflict or ambiguity.

"WealthQuest," "we," "us," "our," "the Company" — the applicable Contracting Entity (Section 3).
‍"Customer" — an individual who purchases products or services through the WealthQuest platform.
‍"IBO" — an individual enrolled to refer Customers and earn compensation under the Sales Compensation Plan.
‍"Applicant" — an individual who has accepted the IBO Agreement and paid the Activation Fee and first Monthly License Fee, but whose identity verification has not yet cleared. Verification is a two-part requirement: both WealthQuest's own check through Sumsub and PayQuicker's independent check must clear. An Applicant is not an IBO: until verification clears, no BV, no Rank, and no compensation accrues. The Applicant's placement position is reserved at payment and is activated on verification, so tree position follows enrollment order rather than verification speed (Part I §13).
‍"Sponsor" — the IBO whose referral link or ID a new enrollee identifies as the source of their enrollment.
‍"Personal Data" — any information relating to an identified or identifiable natural person.
‍"Biometric Identifiers" — data such as facial geometry derived from a scan of physical characteristics, used to identify an individual (Section 5).
‍"Processing" — any operation performed on personal data, including collection, storage, use, disclosure, and deletion.
‍"Data Controller" — the entity determining the purposes and means of processing personal data; WealthQuest is the data controller for the processing described in this Policy, except where stated otherwise (Section 8)
."Data Processor" — a third party processing personal data on WealthQuest's behalf and under its instructions (Section 8).
‍"Sub-processor" — a data processor a Data Processor itself engages to help fulfil its obligations to WealthQuest (for example, Microsoft Azure, engaged by Pillars). WealthQuest requires each Data Processor to obtain WealthQuest's prior authorization before engaging a new Sub-processor.
‍"Contracting Entity" — the WealthQuest entity you contract with based on your country of residence at enrollment (Section 3).
‍"Affiliated Companies" — WealthVentures, LLC, a Nevada limited liability company that is a separate company under common ownership and control with WealthQuest, LLC. Neither company is a subsidiary of the other. WealthVentures, LLC operates the WealthVentures Platform and licenses it to WealthQuest, LLC. Data sharing between WealthQuest, LLC and WealthVentures, LLC is governed by a written data processing / data sharing agreement between the two companies (Section 8). WealthVentures, LLC is currently the only Affiliated Company; this Policy will be updated if others are added.

WealthQuest currently operates through a single Contracting Entity:WealthQuest, LLC, 5717 Legacy Dr, Plano, TX 75024-3689, USA — the Contracting Entity for every market WealthQuest currently serves, worldwide, including the United States, the EU/EEA, United Kingdom, and Switzerland. Your rights and the rules specific to you are in Annex A, and in Annex B as well if you are located in the EU/EEA, United Kingdom, or Switzerland.Which entity is your controller. WealthQuest, LLC is the data controller for all Customers and IBOs covered by this Policy, worldwide — including for data generated through your use of the WealthVentures membership on the WealthQuest platform. WealthVentures, LLC is a separate legal entity from WealthQuest, LLC (Section 2, "Affiliated Companies"); the two share data with each other only as described in Section 8.Future market-specific entities. WealthQuest currently serves all markets through this single Contracting Entity. As WealthQuest forms additional Contracting Entities dedicated to specific markets, this Policy will be updated with a corresponding new annex covering that entity's specific legal regime and rights, and the audience for the affected annex(es) will be split by location accordingly (Part IV).

Identity and verification data: full legal name, date of birth, nationality, residential address, government-issued ID documents, and — for IBOs — selfie/liveness biometric data collected through our KYC/AML verification provider (Section 5, Section 8).Enhanced due diligence data: for IBOs, proof of address or source-of-funds/source-of-wealth documentation, requested where a compliance review flags the need for enhanced checks or in connection with a large or unusual payout.Contact data: email address, phone number, mailing address.Financial data: payment and payout account information. WealthQuest itself never directly handles Customer card data — payment is processed exclusively through WealthQuest's designated payment processor — but WealthQuest does hold IBO payout-related account information.Billing and transaction event data: records of each payment attempt tied to a subscription or order — retries, failures, and successes, with timestamps — kept separately from the account-level payment information above.Placement-tree data: for IBOs, information about your position in the compensation plan's placement tree, and limited information about your downline (name, rank, activity status, volume) as needed to support your team.Device and usage data: collected automatically via cookies and similar technologies, including analytics and advertising identifiers (Section 9).Marketing preferences: your choices regarding email and SMS communications (Section 14).Consent and agreement records: timestamps of your acceptance of the Terms, this Policy, and marketing consent, and — for IBOs — the signed IBO Agreement record.Images and recordings: photos and video taken at WealthQuest company events, and any resharing of related participant content on WealthQuest's social media channels.Tax information: for IBOs, tax identification number and related income information, where required for compensation reporting (see the tax-reporting section of Annex A).Support and correspondence data: the content of communications you send to WealthQuest's customer support or compliance teams, including attachments, and records of how those inquiries were resolved.Inferred data: rank tier, activity-status flags, and similar classifications WealthQuest derives from your placement-tree and transaction data, rather than collects directly from you.
‍Sponsor sharing — what's visible and what isn't. Where you are referred to WealthQuest by an IBO (your Sponsor), the following limited information about your enrollment may be visible to that Sponsor: your name, enrollment date, rank, and business-relevant activity/sales volume. WealthQuest does not make visible to your Sponsor: your Social Security number or other government ID, banking or payment details, your home address, or the biometric verification data described in Section 5. Direct contact between IBOs is handled through the platform's own messaging tools rather than by exporting raw contact information.
‍Images and recordings. By registering for or attending a WealthQuest company event, you consent to WealthQuest capturing photos and video of your participation and using that content for promotional purposes, including resharing on WealthQuest's official social media channels. This consent is captured as part of the event registration process. If you do not wish to be photographed or recorded, you may notify WealthQuest in writing before the event, or identify yourself to event staff on-site so reasonable steps can be taken to exclude you from official coverage.

Booking travel often means giving us information about people other than yourself — a spouse, family member, or other travel companion. Where you use the Platform to search, plan, or book travel for someone else, you may provide us with limited personal data about that person, such as their name, date of birth, and any travel-document, dietary, or accessibility information a specific booking requires.By providing that information, you confirm that you have the authority to share it and, where the person is a minor, that you are their parent or legal guardian or otherwise authorized to provide their information for the booking. WealthVentures uses travel-companion data only to complete and support the booking it was provided for, and does not use it to create a separate account or to send that person direct marketing. A Supplier that collects a companion's information directly to fulfill a booking (Section 9) does so under its own privacy terms, not this Policy.

KYC/AML verification records: retained for as long as the account remains active, and for 5 years after account closure or a declined application, consistent with the KYC/AML Statement.
Biometric identifiers: destroyed within 3 years of your last interaction with WealthQuest, or sooner once the verification purpose has been satisfied, whichever is earlier (Section 5).
General account and transaction data: retained for up to seven (7) years post-termination.Prospect data from a Sponsor submission that does not result in a completed enrollment: retained for 90 days from submission, then deleted, unless you complete enrollment yourself before that window closes (Section 6).
Marketing data: retained until consent is withdrawn, or after 3 years of inactivity.
Support and correspondence data: retained for 3 years after the inquiry is resolved.
Session-recording data (Clarity): 30 days, then permanently deleted (Section 9).Images and recordings: retained for the term of the event-registration consent described in Section 4, or until you notify WealthQuest to stop use of your likeness, whichever is earlier.
At the end of a retention period, data is either securely deleted or irreversibly anonymized so it can no longer be linked back to you; anonymized data may be kept indefinitely for aggregate reporting and analytics.

Certain US states — including Illinois (the Biometric Information Privacy Act, 740 ILCS 14/), Texas (the Capture or Use of Biometric Identifier Act), and Washington — impose specific requirements on the collection of biometric identifiers, such as the facial geometry data collected during IBO identity verification. Where these laws apply, WealthQuest obtains your written consent — which may be given electronically — before collecting biometric identifiers, maintains the retention schedule described in Part I §5, and does not sell, disclose, or profit from your biometric data except as necessary to complete verification or as required by law.

An IBO who is subject to US tax-reporting requirements has commission-type compensation reported on Form 1099-NEC, or, where payouts are processed through a third-party settlement organization, on Form 1099-K where applicable reporting thresholds are met.An IBO resident outside the United States is subject to the tax-reporting rules of their own jurisdiction rather than to US information reporting. WealthQuest collects the tax documentation that each jurisdiction requires — for example, a taxpayer identification number and the applicable US tax form from a US payee, and the equivalent tax identification, residency, or self-certification documentation from an IBO resident elsewhere — and uses that documentation only for compensation reporting and related compliance purposes.

As part of KYC/AML onboarding, an Applicant's identity verification may be processed automatically, with up to two automated verification attempts before the application is escalated to manual review. Where applicable automated-decision-making regulations apply to a significant decision — such as one affecting access to a financial or compensation account — WealthQuest provides the notice, opt-out, and appeal rights those regulations require.

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), and similar laws in other US states, you have the right to know what personal data WealthQuest holds about you, to request correction or deletion of it, and to opt out of "sharing" for cross-context behavioral advertising, even where no money changes hands.WealthQuest does not sell personal data. Where WealthQuest's use of advertising pixels constitutes "sharing" under CCPA/CPRA, California residents (and residents of other states with similar laws) may opt out at any time via the "Do Not Sell or Share My Personal Information" / "Your Privacy Choices" link in the website footer. WealthQuest also honors the Global Privacy Control (GPC) signal as a valid opt-out request where technically supported.
‍Beyond California. Residents of Virginia, Colorado, Connecticut, and other states with comprehensive privacy laws have comparable rights, including the right to opt out of targeted advertising and profiling.
‍California Shine the Light. California residents may request, once per calendar year, a list of any third parties WealthQuest has disclosed personal data to for those third parties' own direct marketing purposes. WealthQuest does not disclose personal data to third parties for their own independent marketing purposes, so such a request would typically return no responsive disclosures.
‍Response timeframe. WealthQuest will respond to a CCPA/CPRA rights request within 45 days of receipt, extendable by a further 45 days for complex requests with notice to you. WealthQuest will not deny goods or services, charge a different price, or provide a different level of service to anyone who exercises these rights.

Every commercial email identifies WealthQuest as the sender, includes a valid physical postal address, and provides a working unsubscribe mechanism honored within 10 business days of your request, at no cost to you, consistent with the US CAN-SPAM Act. SMS marketing consent is captured as express written consent directly from you, consistent with the US TCPA. A Sponsor submitting your contact information to initiate your enrollment (Section 6) does not itself establish your prior express consent for WealthQuest's own automated calls or text messages — that consent is captured separately, directly from you, before any such message is sent.IBOs marketing to prospective Customers or recruits on their own behalf must independently comply with applicable telemarketing and text-messaging law, including the TCPA — obtaining their own express consent before texting a prospect and honoring opt-out requests. WealthQuest does not authorize IBOs to text or call prospects using purchased, scraped, or non-consenting contact lists.

Under CCPA/CPRA, a transfer of personal data as part of a merger or acquisition is not itself considered a "sale" or "share" requiring separate opt-out rights, provided the acquiring party continues to use the data consistently with the commitments in this Policy.

WealthQuest, LLC serves Customers and IBOs worldwide, and this Annex A applies in every market WealthQuest currently serves — the United States, and markets outside the United States including Latin America, Asia, Oceania, Canada, the EU/EEA, the United Kingdom, and Switzerland. Annex B does not replace this Annex A for any market: it is an overlay that applies in addition to this Annex A if you are located in the EU/EEA, the United Kingdom, or Switzerland.WealthQuest complies with applicable local data protection law in each market it serves. As WealthQuest launches in additional markets, or forms market-specific Contracting Entities, this section and this Policy will be expanded or updated with country-specific detail as needed (Part IV).

WealthQuest processes your personal data on the following legal bases, corresponding to the purposes listed in Part I §7:
Performance of a contract with you — account creation and management; compensation calculation and payout; support and correspondence (GDPR Article 6(1)(b));
Compliance with a legal obligation — KYC/AML identity verification; tax reporting; sanctions and eligibility screening (GDPR Article 6(1)(c));
WealthQuest's legitimate interests, balanced against your rights — enabling IBOs to see limited downline information; fraud prevention and platform security; platform analytics and improvement, where not based on consent (GDPR Article 6(1)(f)); and
Your consent — marketing communications; use of event photos/video for promotional purposes; non-essential cookies; collection of biometric identifiers, see B.2 (GDPR Article 6(1)(a)), withdrawable at any time as described in B.3.

The facial geometry and other biometric identifiers collected during IBO identity verification (Part I §5) are "special category data" under GDPR Article 9. WealthQuest processes this data only on the basis of your explicit, freely given, written consent, separate from your acceptance of this Policy (GDPR Article 9(2)(a)), consistent with the consent, retention, and disclosure commitments in Part I §5.

In addition to any rights described elsewhere in this Policy, you have the right to:
request access to the personal data WealthQuest holds about you;
request rectification of inaccurate or incomplete data;request erasure of your data ("right to be forgotten"), subject to the retention obligations described in Part I §11;
request restriction of processing in certain circumstances;
receive a copy of the data you provided to WealthQuest in a structured, commonly used, machine-readable format, and have it transmitted to another controller, where technically feasible ("data portability");
object to processing based on WealthQuest's legitimate interests, including profiling, and object to processing for direct marketing purposes at any time, free of charge;
withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal; and
lodge a complaint with the data protection supervisory authority in your country or place of habitual residence — in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC).To exercise any of these rights, contact WealthQuest using the details in Part I §18. WealthQuest will respond within the time limits required by applicable law — generally one month under the GDPR and UK GDPR, extendable by a further two months for complex requests, with notice to you.

As described in Annex A.3, an Applicant's identity verification during KYC/AML onboarding may be processed automatically, but is limited to two automated attempts before mandatory escalation to manual human review — WealthQuest does not make decisions that produce legal or similarly significant effects about you based solely on automated processing, without human involvement. If this changes for any specific process, WealthQuest will provide the safeguards required by GDPR Article 22(3): the right to obtain human intervention, to express your point of view, and to contest the decision.

WealthQuest's infrastructure is hosted on AWS in the United States (Part I §10), so personal data collected from individuals in the EU/EEA, UK, and Switzerland is transferred to, and processed in, the United States — a country that does not have a general EU adequacy decision. WealthQuest relies on the European Commission's Standard Contractual Clauses (SCCs) as its transfer safeguard for these transfers, together with the UK International Data Transfer Addendum for transfers from the United Kingdom and Switzerland's recognized equivalent safeguards for transfers from Switzerland. A copy of the relevant safeguard is available on request through the contact in Part I §18.

WealthQuest, LLC has designated Jürgen Pulvermüller as its representative for data protection purposes in each of the three jurisdictions covered by this Annex B, in addition to WealthQuest, LLC itself:
as WealthQuest, LLC's representative in the European Union for the purposes of Article 27 of the GDPR;as WealthQuest, LLC's representative in the United Kingdom for the purposes of Article 27 of the UK GDPR; and
as WealthQuest, LLC's representative in Switzerland for the purposes of the Swiss FADP.
Each designation is a separate appointment for the jurisdiction named, made by WealthQuest, LLC. These appointments will remain in place until WealthQuest's European operations grow to a point where a dedicated appointee is designated to succeed them in any given jurisdiction. The representative can be reached through the contact in Part I §18, which is monitored for representative correspondence as well as for direct rights requests.

WealthQuest has assessed its processing activities against the criteria in GDPR Article 37, UK GDPR Article 37, and Article 10 of the Swiss FADP and, based on the current scale and nature of its operations, has determined that formal designation of a Data Protection Officer is not presently required. WealthQuest will revisit this assessment, and designate a Data Protection Officer if required, as its EU/UK/Swiss operations scale; until then, questions about this Policy or WealthQuest's data protection practices can be directed to the contact in Part I §18.

The retention schedule in Part I §11 applies equally to your data and reflects the GDPR/UK GDPR storage-limitation principle. WealthQuest's 18-and-older platform minimum (Part I §15) exceeds the GDPR and UK GDPR's data subject consent-age thresholds (16, or as low as 13 depending on EU member state), so no additional age-verification step applies under this Annex.