Privacy Policy

Effective Date: February 4, 2026

Table of contents

Introduction

The Vibes Company Inc. and its subsidiaries—Carry Advisors LLC, Global Carry LLC (collectively, “Company,” “we,” “us,” or “our”)—respect your privacy and are committed to protecting it through compliance with this policy.

Privacy Notice

Who We Are

Who is providing this notice?
The companies that are covered by this notice (together, “Carry”) include:

The Vibes Company Inc. dba “Carry”
Carry Advisors LLC
Global Carry LLC

These affiliated companies share information with each other as described in this notice. We do not share your nonpublic personal information with Silly Money LLC, our affiliated financial media company.

Note for Investment Advisory/Brokerage Clients: If you are a client of Carry Advisors LLC and Global Carry LLC, you will receive this Privacy Notice in accordance with Regulation S-P when you open your advisory and brokerage accounts. This notice governs the collection, use, and disclosure of your nonpublic personal information in connection with your investment advisory account and brokerage account.

What does Carry do with your personal information?

Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some—but not all—sharing and requires us to tell you how we collect, share, and protect your information. Please read this notice carefully to understand what we do

What?
The types of personal information we collect and share depend on the product or service you have with us. This information include:

Social Security number and income information
Tax return information and tax transcripts
Asset holdings, risk-tolerance, and suitability information
Account balances and account transactions

When you are no longer our customer, we continue to share your information as described in this notice.

How?
All financial companies need to share customers’ personal information to run their everyday business. In the table below we list the reasons financial companies can share their customers’ personal information; whether Carry shares; and whether you can limit this sharing.

Reasons we can share your personal information	Does Carry share?	Can you limit this sharing?
For our everyday business purposes — such as to process your transactions; maintain your accounts; respond to court orders and legal investigations; or report to credit bureaus	Yes	No
For compliance and supervisory purposes — e.g., to share account information with non-affiliated broker-dealers, trust companies, bank partners, or investment advisers in order to meet FINRA / SEC / BSA rules	Yes	No
For our marketing purposes — to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	N/A
For our affiliates’ everyday business purposes — information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes — information about your creditworthiness	No	N/A
For our affiliates to market to you	Yes	Yes
For nonaffiliates to market to you	No	N/A

To limit our sharing, email support@carry.com with “Privacy Opt-Out” in the subject line.

Please Note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing. Email support@carry.com.

What We Do

How does Carry protect my personal information?
We use security measures that comply with federal law. These include computer safeguards, encryption in transit and at rest, secure data centers, and policies limiting employee access to only those who need the information to service your account.

How does Carry collect my personal information?
We collect your personal information, for example, when you:

• Open an account or perform transactions

• Provide employment or income information

• Tell us where to send or deposit money

• Upload tax documents such as tax transcripts

• Use the Carry Tax Assistant (AI-powered tax analysis tool)

We also obtain information from third-party vendors, affiliates, and other companies (for instance, when verifying your identity under anti-money-laundering rules).

Why can’t I limit all sharing?
Federal law gives you the right to limit only:

1. Sharing for non-affiliates to market to you.

2. Sharing for affiliates’ everyday business purposes—information about your creditworthiness;

3. Affiliates from using your information to market to you; and

Definitions

Affiliates
Companies related by common ownership or control. Our affiliates include:

The Vibes Company Inc. dba “Carry” (parent)
Carry Advisors LLC (registered investment adviser)
Global Carry LLC (broker-dealer)
Silly Money LLC (media company)

Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Non-affiliates we share your personal information with include service providers and vendors, banking partners, other financial institutions, data processors, and identity verification services.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Carry, Carry Advisors LLC, and Global Carry LLC currently does not jointly market.

Other Important Information

Carry does not and will not sell consumer personal information in the traditional and colloquial sense of the word “sale.” Carry does use targeted advertising technology on its website, which under some state privacy laws may be considered a “sale” or “share” of your information. However, Carry does not exchange any client personal information for monetary payments.

Full Privacy Policy

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.carry.com (our “Website”), related websites, and other offerings, including the investment advisory services provided by our subsidiary Carry Advisors LLC and the brokerage services introduced by Global Carry LLC (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website;
In email and other electronic messages between you and this Website;
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;
From our subsidiary, Carry Advisors LLC, in connection with its provision of investment advisory services;
From our subsidiary, Global Carry LLC, in connection with its introduction of brokerage services;
From The Vibes Company Inc., in connection with its provision of tax planning services and technology platform services; and
Through AI-powered tools and features, including the Carry Tax Assistant (defined below).

Our Affiliated Companies

The Vibes Company Inc. is a Delaware corporation and the parent company of the following wholly-owned subsidiaries:*

Carry Advisors LLC – Registered investment adviser
Global Carry LLC – Introducing broker-dealer
Silly Money LLC – Financial media company producing educational content

*Carry Tax LLC no longer offers or markets any direct or indirect tax planning or tax filing services.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Services. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@carry.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

By which you may be personally identified, such as name, postal address, email address, telephone number, Social Security Number, date of birth, and financial account information (“Personal Information”);
That is about you but individually does not identify you, such as tracking and usage information about your location, demographics, and use of the Services (“Non-Personal Information”);
About your internet connection, the equipment you use to access our Services, and usage details;
Financial information necessary to provide our Services, including income information, tax return data, investment account information, and transaction history; and
Information contained in documents you upload to our Services, including tax transcripts and other tax-related documents.

We collect this information:

Directly from you when you provide it to us;
Automatically as you navigate through the site (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies);
From our subsidiaries, Carry Advisors LLC and Global Carry LLC, in connection with their provision of services;
From third-party service providers, including custodians and clearing firms; and
Through AI-powered features that analyze documents you upload.

The types of personal information collected may vary depending on the specific type of account you have, whether you utilize the investment advisory services provided by Carry Advisors LLC, the brokerage services introduced by Global Carry LLC, or the tax planning services provided by The Vibes Company Inc.

AI-Powered Features and Data Processing

The Company offers an AI-powered tax assistant feature (“Carry Tax Assistant”) that allows you to upload tax documents for analysis and receive personalized tax insights. The Carry Tax Assistant is operated by The Vibes Company Inc.

Authorization to Process Data. By interacting with and uploading documents to the Carry Tax Assistant, you explicitly authorize The Vibes Company Inc. to process, store, and analyze your chat history, uploaded documents, and their contents. You further authorize us to transmit this data to our third-party artificial intelligence service providers (“AI Providers”) solely for the purpose of immediate processing. You acknowledge that uploaded documents may contain sensitive personal information, including your name, Social Security Number, income details, and other tax return information (collectively, “Tax Data”).

Third-Party AI Provider Data Practices. We utilize AI Provider services with protective privacy configurations:

No Model Training: Your Tax Data will NOT be used to train, improve, or fine-tune our AI Providers’ artificial intelligence models.
Zero Data Retention: We require our AI Providers to process your Tax Data solely to generate a response and not retain a copy of your uploaded documents or extracted data after the processing request is completed. AI Providers will process data in accordance with the Data Processing Addendum.

Our Data Retention Practices. Unlike our AI Providers, we will retain your chat history, uploaded files, and extracted data for:

Customer Support: To assist with your account inquiries and verify the accuracy of automated insights.
Internal AI Improvement: To test, train, tune, and improve our internal artificial intelligence models and document identification software.
Record Keeping: To maintain necessary records associated with your user profile in compliance with our data retention policies and applicable laws.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Services and their contents to you;
To provide you with information, products, or services that you request from us;
To fulfill any other purpose for which you provide it;
To provide you with notices about your account, including expiration and renewal notices;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
To notify you about changes to our Services or any products or services we offer or provide through them;
To allow you to participate in interactive features on our Services;
To provide the investment advisory services offered by Carry Advisors LLC;
To provide the brokerage services introduced by Global Carry LLC;
To provide the tax planning services offered by The Vibes Company Inc.;
To provide AI-powered analysis and insights through the Carry Tax Assistant;
In any other way we may describe when you provide the information; and
For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates, as described in the “Sharing Information Among Affiliates” section below;
To contractors, service providers, and other third parties we use to support our business, including:
- Custodians and clearing firms that hold and process your investment accounts;
- AI Providers that process data through the Carry Tax Assistant;
- Payment processors, identity verification services, and other operational service providers;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Vibes Company Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by The Vibes Company Inc. about our Services’ users is among the assets transferred;
To fulfill the purpose for which you provide it;
For any other purpose disclosed by us when you provide the information; and
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Vibes Company Inc., our customers, or others.

The Vibes Company Inc. and its subsidiaries may share your personal information with each other as follows:

The Vibes Company Inc., Carry Advisors LLC, and Global Carry LLC may share your nonpublic personal information with each other for purposes related to servicing your account, providing integrated financial and tax planning services, marketing products and services offered by these entities, and for other purposes permitted by law. These entities do not share your nonpublic personal information with Silly Money LLC.

Silly Money LLC may share information it collects with The Vibes Company Inc., Carry Advisors LLC, and Global Carry LLC for purposes related to referring users to our financial services, marketing, and for other purposes permitted by law.

We share your nonpublic personal information with nonaffiliated third parties that perform services on our behalf. These service providers are contractually obligated to:

Use the information only for the purposes for which it was disclosed;
Maintain the confidentiality of the information;
Implement appropriate safeguards to protect the information; and
Not use or disclose the information for any other purpose, including their own marketing purposes.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. These measures include:

Industry-standard security protocols and encryption of sensitive data;
Regular security audits and vulnerability assessments;
Access controls limiting employee access to personal information on a need-to-know basis;
Secure data centers with physical security measures;
Encryption of data in transit and at rest;
Employee training on data privacy and security practices; and
Contractual requirements for service providers to maintain appropriate safeguards.

However, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk.

Your Rights and Choices

You have certain rights regarding your personal information, which may vary depending on your jurisdiction. To the extent provided by applicable law, you may:

1. Request access to the personal information we maintain about you and request details about how we process it;

2. Request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes;

3. Request that we update or correct inaccuracies in your personal information;

4. Request that we block or delete your personal information from our database;

5. Opt out of sharing your personal information with unaffiliated or non-agent third parties for promotional purposes;

6. Opt out of marketing communications from Carry; and

7. Request deletion of data processed through the Carry Tax Assistant (subject to our legal retention obligations).

To exercise any of these rights or to make any other inquiries about this privacy policy, please contact us using the information provided in the Contact Information section below. We may take steps to verify your identity before granting you access to your personal information or fulfilling your request to protect your privacy and maintain security.

Please note that your rights may be subject to certain limitations and exceptions under applicable law. In some cases, we may charge a fee to fulfill your request, as permitted by law.

California Residents: If you are a California resident, you have the right under California Civil Code Section 1798.83 to request certain information regarding our disclosure (if any) of personal information to third parties for their direct marketing purposes. To make such a request, please email us or write to us at the address provided in the Contact Information section.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Services and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

The Vibes Company Inc.
10 Grand Street, STE 1800
Brooklyn, NY 11249
Email: support@carry.com