Effective Date: May 18, 2026

Last Updated: May 28, 2026

Introduction

Athira Network LLC dba Ellner Financial Network is an employee benefits, insurance consulting, and financial services support firm that works with employers, business owners, executives, individuals, insurance carriers, brokers, consultants, and financial advisors to provide employee benefit planning, insurance-related products and services, executive benefits, wellness solutions, and related consulting services.

Our services may include, without limitation:

• Group health and welfare benefit consulting

• Executive and supplemental benefit planning

• Retirement and deferred compensation consulting

• Insurance product consulting and placement

• Wellness and employee engagement programs

• Benefits administration support

• Collaboration with licensed insurance professionals and financial advisors

• Educational seminars and informational services

Because our services may involve insurance, financial, healthcare-related, and employee information, we are committed to protecting personal information and maintaining commercially reasonable privacy and security safeguards. This Privacy Policy is intended to comply with applicable federal and state privacy laws and industry standards relevant to employee benefits, insurance consulting, and related financial services operations.

Athira Network LLC dba Ellner Financial Network (“Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you provide through our website, electronic communications, and related services.

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you:

• Visit our website(s)

• Submit forms online

• Communicate with us through internet email

• Subscribe to newsletters or marketing communications

• Request products, services, consultations, or information

• Interact with our digital advertising, social media, or online platforms

By using our website or communicating with us electronically, you agree to the terms of this Privacy Policy.

1. Information We Collect

We may collect the following categories of information:

A. Personal Information You Provide
Information you voluntarily provide may include:

• Name

• Company name

• Job title

• Mailing address

• Telephone number

• Email address

• Payment or billing information

• Information submitted through contact forms

• Information included in emails or attachments

• Any other information you choose to provide

B. Automatically Collected Information
When you visit our website, we may automatically collect:

• IP address

• Browser type

• Device type

• Operating system

• Website usage data

• Pages visited

• Date and time of access

• Referring website addresses

• Cookies and tracking technologies

2. How We Use Information
We may use collected information for business, insurance, consulting, employee benefits, and financial-services-related purposes, including to:

• Evaluate and recommend employee benefit solutions

• Provide insurance consulting and brokerage services

• Assist with underwriting or insurance applications

• Coordinate with insurance carriers, TPAs, payroll providers, and benefits administrators

• Collaborate with financial advisors, CPAs, attorneys, and professional advisors authorized by clients

• Administer employee benefit and wellness programs

• Facilitate enrollment and plan administration

• Communicate regarding policies, claims, renewals, or coverage matters

• Provide executive benefits and deferred compensation consulting

• Respond to inquiries and service requests

• Send newsletters, educational materials, or marketing communications

• Improve website functionality and client experience

• Analyze website traffic and business trends

• Maintain security and prevent fraud

• Comply with legal, regulatory, licensing, and contractual obligations

• Enforce agreements, policies, and business practices

We may also use collected information to:

• Provide products and services

• Respond to inquiries and requests

• Communicate with you regarding services

• Send newsletters, updates, or marketing communications

• Improve website performance and user experience
• Personalize content and communications
• Analyze website traffic and trends
• Process transactions

• Maintain security and prevent fraud
• Comply with legal obligations

• Enforce our terms and policies

3. Email Communications

By providing your email address, you consent to receive communications from us electronically.

These communications may include:

• Service-related notices

• Appointment confirmations

• Administrative messages

• Marketing emails

• Promotional offers

• Newsletters

• You may opt out of marketing emails at any time by:

• Clicking the “unsubscribe” link in any marketing email

• Contacting us directly using the information below

• Please note that even if you opt out of marketing communications, we may still send transactional or administrative emails.


4. Cookies and Tracking Technologies

Our website may use:

• Cookies

• Web beacons

• Pixels

• Analytics tools

• Session tracking technologies

These technologies help us:

• Understand website usage

• Improve functionality

• Customize user experiences

• Measure marketing effectiveness

• Maintain security

You may control cookie settings through your browser preferences. Disabling cookies may affect website functionality.

5. Analytics and Advertising

We may use third-party analytics and advertising providers, including but not limited to:

• Google Analytics

• Meta/Facebook advertising tools

• LinkedIn advertising tools

• Other analytics or advertising platforms

These providers may collect information regarding your interaction with our website and advertisements.

You can learn more about Google Analytics by visiting Google’s privacy resources.

6. How We Share Information

• We do not sell personal information to third parties.

• Because of the nature of our employee benefits and insurance consulting services, we may share information with trusted third parties as reasonably necessary to provide requested services or conduct business operations.

• These parties may include:

• Insurance carriers and underwriters

• Third-party administrators (TPAs)

• Employee benefits enrollment platforms

• Payroll providers and HR platforms

• Financial advisors and investment professionals

• Accountants, attorneys, and tax advisors

• We llness and employee engagement vendors

• Technology and software providers

• Website hosting and IT service providers

• Email communication and CRM providers

• Government agencies or regulatory authorities where required by law

Information may be shared for purposes including:

• Insurance quoting and underwriting

• Policy administration and renewals

• Benefits enrollment and administration

• Claims processing support

• Regulatory compliance

• Client-requested coordination among professional advisors

• Business operations and service delivery

We may also disclose information:

• To comply with legal obligations

• To protect our legal rights or property

• To investigate fraud, cybersecurity threats, or unauthorized activity

• In connection with mergers, acquisitions, reorganizations, or asset transfers

Third-party service providers receiving personal information are expected to maintain reasonable confidentiality and security protections consistent with applicable laws and contractual obligations.

We do not sell personal information to third parties.

We may share information with:

• Service providers and vendors

• Website hosting providers

• Email marketing providers

• Payment processors

• Legal or regulatory authorities

• Professional advisors

• Successors in connection with mergers, acquisitions, or asset sales

We may disclose information when required by law or when necessary to:

• Protect our rights

• Comply with legal obligations

• Respond to lawful requests

• Prevent fraud or security threats

7. Data Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information.

However, no method of internet transmission or electronic storage is completely secure. Therefore, we cannot guarantee absolute security.

8. Data Retention

We retain personal information for as long as reasonably necessary to:

• Fulfill business purposes

• Provide services

• Comply with legal obligations

• Resolve disputes

• Enforce agreements

Retention periods may vary depending on the type of information and applicable legal requirements.

9. Your Privacy Rights

Depending on your state of residence, you may have rights regarding your personal information, including the right to:

• Access personal information

• Correct inaccurate information

• Request deletion of information

• Opt out of certain data processing activities

• Limit use of sensitive personal information

• Appeal certain privacy-related decisions

To exercise applicable rights, contact us using the information below.

We may verify your identity before processing requests.

10. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

California residents may request:

• Disclosure of categories and specific pieces of personal information collected

• Deletion of personal information

• Correction of inaccurate information

• Information regarding data sharing practices

California residents may also have the right to opt out of certain sharing activities.

To exercise these rights, contact us using the information below.

11. Children’s Privacy

Our website and services are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18.

If we become aware that such information has been collected, we will take appropriate steps to delete it.

12. Third-Party Websites

Our website or emails may contain links to third-party websites.

We are not responsible for the privacy practices, policies, or content of third-party sites. Users should review the privacy policies of those websites independently.

13. International Users

Our services are intended for users located in the United States.

If you access our website from outside the United States, you understand that your information may be transferred to and processed in the United States.

14. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time.

Changes will become effective upon posting the updated Privacy Policy on our website with a revised “Last Updated” date.

Continued use of our website or services after updates constitutes acceptance of the revised polic

15. Contact Information

If you have questions regarding this Privacy Policy or our privacy practices, please contact:

Athira Network LLC dba Ellner Financial Network

Email: [email protected]

Website: www.ellnerfinancialnetwork.com

16. HIPAA / Health Information Privacy

If applicable, Athira Network LLC dba Ellner Financial Network may collect, receive, maintain, or transmit certain health-related information in connection with employee benefits, wellness programs, insurance-related services, healthcare consulting, or other services.

To the extent applicable, we strive to comply with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and related regulations governing the privacy and security of protected health information (“PHI”).

Health-related information may be used or disclosed:

• To provide requested services

• To administer employee benefit or insurance-related programs

• For payment and healthcare operations

• As authorized by the individual

• As otherwise permitted or required by law

We implement reasonable administrative, technical, and physical safeguards designed to protect health-related information from unauthorized access, disclosure, or misuse. If HIPAA applies to your relationship with us, additional notices regarding privacy practices may be provided separately as required by law.

17. Financial Services and GLBA Privacy Notice

Because Athira Network LLC dba Ellner Financial Network provides insurance consulting, employee benefits services, executive benefits planning, and related financial-services support, certain federal and state financial privacy laws may apply to aspects of our operations.

We may collect nonpublic personal information in connection with:

• Insurance applications and enrollment

• Employee benefit consulting engagements

• Executive compensation and deferred compensation planning

• Financial wellness and retirement-related services

• Client onboarding and service administration

Information we may collect includes:

• Name, address, telephone number, and email address

• Date of birth and identifying information

• Employment and compensation information

• Insurance and benefits information

• Financial and tax-related information

• Health-related information where permitted by law

• Transaction and account information

• Information submitted through applications, forms, or communications

We may obtain information from:

• Clients and prospective clients

• Employers and plan sponsors

• Insurance carriers and administrators

• Financial advisors and licensed professionals

• Service providers and vendors

• Consumer reporting agencies where legally permitted

We do not disclose nonpublic personal information to nonaffiliated third parties except:

• As necessary to provide requested services

• To insurance carriers, underwriters, and administrators

• To licensed financial professionals involved in client services

• To service providers operating on our behalf

• As permitted or required by law

• With client authorization or direction

We maintain commercially reasonable physical, electronic, and procedural safeguards designed to protect nonpublic personal information in accordance with applicable privacy and security laws, including the Gramm-Leach-Bliley Act (“GLBA”), where applicable.

If Athira Network LLC dba Ellner Financial Network provides financial, insurance, advisory, employee benefits, retirement planning, or related financial services, we may collect nonpublic personal information in connection with those services.

Information we may collect includes:

• Contact information

• Financial account information

• Employment information

• Insurance-related information

• Transaction history

• Tax-related information

• Information received from applications or forms

We may collect this information from:

• You directly

• Financial institutions

• Insurance carriers

• Employers

• Service providers

• Consumer reporting agencies where permitted by law

We do not disclose nonpublic personal information to nonaffiliated third parties except:

• As permitted or required by law

• To process transactions or provide services

• To service providers operating on our behalf

• To comply with legal or regulatory obligations

We maintain physical, electronic, and procedural safeguards designed to protect nonpublic personal information in accordance with applicable federal and state regulations, including the Gramm-Leach-Bliley Act (“GLBA”), where applicable.

18. SMS and Text Messaging Communications

By providing your mobile telephone number and opting into SMS communications, you expressly consent to receive text messages from Athira Network LLC dba Ellner Financial Network, including:

• Appointment reminders

• Account notifications

• Customer service communications

• Marketing and promotional messages

• Event invitations

• Service updates

Message frequency may vary.

Message and data rates may apply depending on your mobile carrier and plan.

Consent to receive SMS messages is not a condition of purchasing any goods or services.

You may opt out of SMS communications at any time by:

• Replying “STOP” to any message

• Contacting us directly using the information provided below

You may reply “HELP” for assistance.

We are not responsible for delayed or undelivered messages.

Mobile information collected for SMS communications will not be sold or shared with third parties for their own marketing purposes.

19. California Privacy Rights (CCPA/CPRA)

If you are a resident of California, you may have certain rights under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

Subject to applicable exceptions, California residents may have the right to:

• Know the categories of personal information we collect
• Know the sources from which personal information is collected
• Know the business purposes for collecting or sharing information
• Know the categories of third parties with whom information is shared
• Request access to specific pieces of personal information
• Request deletion of personal information
• Request correction of inaccurate personal information
• Limit the use and disclosure of sensitive personal information
• Opt out of the sale or sharing of personal information, if applicable
• Avoid discriminatory treatment for exercising privacy rights

We may verify your identity before processing requests. Authorized agents may submit requests on behalf of California residents where permitted by law. To exercise California privacy rights, contact us using the information provided above.

20. State Privacy Rights

Residents of certain states may have additional privacy rights under applicable state consumer privacy laws.

These states may include, but are not limited to:

• California
• Colorado
• Connecticut
• Delaware
• Indiana
• Iowa
• Minnesota
• Montana
• Nebraska
• New Hampshire
• New Jersey
• Oregon
• Tennessee
• Texas
• Utah
• Virginia

Depending on your state of residence, you may have rights to:

• Confirm whether we process your personal information
• Access personal information
• Correct inaccuracies
• Delete personal information
• Obtain copies of personal data
• Opt out of targeted advertising
• Opt out of profiling or certain automated decision-making
• Opt out of certain data sharing practices
• Appeal denied privacy requests

To submit a privacy rights request, please contact us using the contact information above.

We reserve the right to verify your identity before processing requests.

21. Email Security Disclaimer

Electronic mail (email) communications may not always be secure.

Although we take commercially reasonable steps to protect electronic communications, we cannot guarantee the security or confidentiality of information transmitted through email or the internet.

Users should avoid transmitting highly sensitive or confidential information through unsecured email communications unless appropriate encryption or secure transmission methods are used.

By communicating with us electronically, you acknowledge and accept these inherent risks.

22. Data Breach Notification

In the event of a data security incident involving personal information, Athira Network LLC dba Ellner Financial Network will take commercially reasonable steps to investigate, mitigate, and respond appropriately. Where required by applicable law, affected individuals and regulatory authorities may be notified in accordance with state and federal data breach notification requirements.

23. Do Not Track Signals

Some web browsers may transmit “Do Not Track” (“DNT”) signals.

Because there is currently no universally accepted standard for responding to DNT signals, our website may not respond to such browser settings or mechanisms.

24. Accessibility Statement

Athira Network LLC dba Ellner Financial Network is committed to making our website and digital communications reasonably accessible to individuals with disabilities.

If you experience difficulty accessing content on our website or require assistance, please contact us using the information above.