Privacy Policy & Terms of Service

ThinkNirvana Foundation · AIPEP401K · Nirvana Ledger LLC

Effective date: June 2026 · Last updated: June 17, 2026
Plain English summary: We collect only what we need to operate the waitlist and plan. We never sell your data. You can ask us to delete it anytime.

Who we are

ThinkNirvana Foundation, Inc. ("ThinkNirvana," "we," "us," or "our") is a Maryland nonprofit corporation operating as a Pooled Plan Provider under ERISA §413(e). We operate AIPEP401K, a pooled employer 401(k) plan. Technology infrastructure is provided by Nirvana Ledger LLC under license.

This Privacy Policy covers ThinkNirvana Foundation, AIPEP401K, and the websites aipep401k.com and thinknirvana.org.

What we collect

Waitlist and inquiry forms

When you join the AIPEP401K waitlist or contact us, we collect:

Plan participants (when the plan launches)

For enrolled participants, we collect personal and financial information required by ERISA and IRS regulations, including name, Social Security Number, date of birth, compensation, and contribution elections. This information is encrypted at rest using AES-256 encryption and is never stored in plaintext.

Website usage

We use Google Analytics to understand how visitors use our sites. This includes page views, time on site, and general geographic region. We do not use advertising trackers or sell browsing data.

How we use your information

What we never do

Data storage and security

Waitlist data is stored in Google Sheets, accessible only to ThinkNirvana Foundation staff. Participant plan data (when the plan launches) is encrypted at rest using AES-256 via pgcrypto and transmitted over TLS 1.3. Bank account connections are verified via Plaid — we never store full account numbers.

Your rights

You have the right to:

To exercise any of these rights, email hello@thinknirvana.org with the subject line "Privacy Request."

Cookies

Our websites use minimal cookies — only those required by Google Analytics for usage measurement. We do not use advertising cookies or cross-site tracking.

Changes to this policy

We may update this policy as our services develop. Material changes will be noted at the top of this page with an updated effective date. Continued use of our sites constitutes acceptance of the updated policy.

Privacy contact

ThinkNirvana Foundation, Inc.

Olney, Maryland

Email: hello@thinknirvana.org

Subject line: "Privacy Request"

⚠️ DRAFT — Compliance review pending. Not yet in effect.
Effective date: June 2026 · Last updated: June 17, 2026
Plain English summary: This site provides information about AIPEP401K and ThinkNirvana Foundation. It is not investment advice. The plan itself is governed by ERISA plan documents, not these terms.

Acceptance of terms

By accessing aipep401k.com or thinknirvana.org (the "Sites"), you agree to these Terms of Service. If you do not agree, please do not use the Sites.

What this site is

These Sites provide general information about ThinkNirvana Foundation and the AIPEP401K pooled employer plan. They are not investment advisory platforms, financial planning tools, or retirement counseling services.

Not investment advice

Nothing on these Sites constitutes investment advice, legal advice, tax advice, or a recommendation to purchase any financial product. Fee comparisons and savings estimates are for illustrative purposes only based on publicly available industry data. Your actual results will vary based on your specific circumstances. Please consult a qualified financial, legal, or tax advisor before making any decisions.

Waitlist and plan enrollment

Joining the waitlist does not constitute enrollment in the AIPEP401K plan and creates no contractual obligation on either party. Actual plan enrollment is governed by a separate Adoption Agreement and Plan Document. Plan availability is subject to regulatory approvals and launch timeline.

Accuracy of information

We make reasonable efforts to keep information on these Sites accurate and current. However, we make no warranties about the completeness, accuracy, or timeliness of any information. SECURE 2.0 tax credit amounts and eligibility are subject to IRS guidance and your specific business circumstances.

Intellectual property

All content on these Sites — including text, design, code, and branding — is owned by ThinkNirvana Foundation, Inc. or Nirvana Ledger LLC and protected by copyright. "AIPEP401K" and "ThinkNirvana" are trademarks pending registration with the USPTO.

Third-party trademarks

Vanguard®, Fidelity®, Empower®, Gusto®, ADP®, Paychex®, and other third-party names referenced on these Sites are trademarks of their respective owners. ThinkNirvana Foundation is not affiliated with, endorsed by, or sponsored by any of these companies.

Limitation of liability

To the maximum extent permitted by law, ThinkNirvana Foundation and Nirvana Ledger LLC shall not be liable for any indirect, incidental, or consequential damages arising from your use of these Sites or reliance on information contained herein.

Governing law

These Terms are governed by the laws of the State of Maryland, without regard to conflict of law principles. Any disputes shall be resolved in the courts of Montgomery County, Maryland.

Changes to these terms

We may update these Terms at any time. Continued use of the Sites after changes are posted constitutes acceptance of the updated Terms.

Questions about these terms

ThinkNirvana Foundation, Inc.

Olney, Maryland

Email: hello@thinknirvana.org

⚠️ DRAFT — Compliance review pending. Not yet in effect.
Effective date: June 2026 · Last updated: June 17, 2026
ERISA §413(e) requires pooled plan providers to maintain certain disclosures. This page provides general disclosure information. Plan-specific disclosures are provided to employers and participants through the formal plan enrollment process.

Plan identity

Plan name: AIPEP 401(k) Pooled Employer Plan

Plan type: Pooled Employer Plan (PEP) — Defined Contribution 401(k)

Pooled Plan Provider: ThinkNirvana Foundation, Inc.

ERISA §413(e) registration: In process — registration being completed with the U.S. Department of Labor prior to first employer enrollment

EIN: To be added upon completion of nonprofit registration

Fiduciary roles

Investment policy

AIPEP 401(k) does not use a 3(38) investment manager. ThinkNirvana Foundation serves as Named Investment Fiduciary and makes all investment decisions directly, consistent with the plan's Investment Policy Statement (IPS). The IPS is available to participating employers upon request.

The plan offers five Vanguard index funds exclusively:

No revenue sharing, sub-transfer agency fees, or 12b-1 fees are accepted from any fund company. The plan receives no compensation from fund providers.

Fee disclosure summary

Full fee disclosure is provided to employers and participants through the formal enrollment documents including the 408(b)(2) disclosure and participant fee disclosure notices. A summary:

Form 5500

As Pooled Plan Provider, ThinkNirvana Foundation files a single master Form 5500 on behalf of all participating employers annually. Individual employers are relieved of their Form 5500 filing obligation upon joining the plan.

Plan documents

The following documents govern plan operations and are available to employers and participants upon request:

Requesting disclosures

Employers, participants, and their authorized representatives may request any plan document or disclosure by contacting us at:

ERISA disclosure requests

ThinkNirvana Foundation, Inc.

Olney, Maryland

Email: hello@thinknirvana.org

Subject line: "ERISA Disclosure Request"

We will respond within 5 business days.