WalletFi - Privacy Statement

WalletFi Privacy Statement

I. Scope of this Privacy Statement

Welcome to StartStopMove, Inc. dba WalletFi ("WalletFi", "us," "we" or "our"). Our privacy statement ("Privacy Statement") describes the types of personal information that are or may be collected, used and disclosed when you access or use the website located at www.walletfi.com (the "Site") and/or order, receive, or otherwise use the services made available by WalletFi, accessed directly or indirectly via a third party financial institution's website or a digital or mobile application/platform ("Service") and is designed to help you understand how we collect, use and share personal information and to assist you in exercising the privacy rights available to you. This Privacy Statement does not govern our collection of personal information through any website, mobile application or other means, other than through the Site. Any capitalized terms used and not defined in this Privacy Statement will have the same meaning as provided in the Terms of Use.

We are a private company, established in the United States, registered at StartStopMove, Inc. Attn: Legal PO Box 30171 Raleigh, NC 27622 United States ("Physical Notice Address") with the contact email address legal@walletfi.com ("Email Notice Address") and for the purposes of the General Data Protection Regulation ("GDPR") we are the data controller.

This Privacy Statement covers both any public-facing Site operated by us (as well as use of the Service provided only to registered users.

In addition, please review our Terms of Use ("Terms") which governs your use of the Site and the Service. By using the Site and Service, you acknowledge that you have read and understood our Privacy Statement and our Terms and accept our collection, use and disclosure of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Statement, please do not use the Service.

We encourage you to review any applicable institutional privacy policies, terms and agreements to see how your personal information may be used or disclosed by that institution.

By accessing the Site or using the Service, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not access or browse the Site, or use the Service.

We encourage you to review this Privacy Statement whenever you access the Site or use the Service, to stay informed about our personal information practices and the ways you can help protect your privacy.

II. Personal Information We Collect

A. Information You Give Us

The types of personal information we may collect from you may include:

User-provided Information. When you create an account or use the Service, you may provide and we may collect what is generally called "personally identifiable" information, such as your name and e-mail address, mailing address, mobile phone number, and demographic information such as gender, interests and location. For example, you may provide us with personal information when you register for an account, use the Service, interact with other users of the Service through communication or messaging features, or send us customer service related requests. Depending on the type of device you are using, we may also allow you to identify yourself when logging on to the Service by providing your thumbprint.

Financial Institution Aggregation. In order for you to benefit from the full functionality of our Service, our Service require access to your financial institution ("FI") account data, including transaction history, balances, and account information. We may access directly, or we may use a third party service provider to facilitate the collection of your FI account data from your FIs, including, but not limited to, accessing your FI account data, including financial transaction data, balances, and activity, and retrieving your FI account data from such third party financial institutions. We do not store your FI account login information.

Information from Other Sources. We may also obtain information, including personally identifiable information, from third parties and sources other than the Service, such as our partners or advertisers. For example, we use Plaid Technologies, Inc. ("Plaid") to gather your data from financial institutions. By using our Service, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid's Privacy Policy (located at https://plaid.com/legal). We may also, at your direction, receive information from third party services that provide a mechanism to share information you have provided to such third party through the use of an application program interface (API), such as Facebook Connect or the Twitter API. If we combine or associate information from other sources with personal information that we collect through the Service, we will treat the combined information as personal information in accordance with this Privacy Statement.

Additional Information: Additional information that you provide to us, including through comments and feedback, messages, emails, posts to public discussion boards, or answers to surveys or questionnaires that you may submit.

B. Automated Information Collection

We may collect certain information about your use of the Site or the Service through the use of tracking technologies or by other passive means. This passively collected information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.

IP Address. IP address can reveal a web user's general location (city, state, country).

Links. The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our products and design.

URLs. When you visit or access the Site, we automatically receive the URL of the site from which you came and the site to which you are going when you leave the Site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Site.

Cookies. When you visit or access the Site, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of the Site by storing user preferences and tracking user trends. Most web browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some customized features available through the Site.

Web Beacons. Web beacons (also known as "pixel tags" or "clear GIFs") are 1x1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Site and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.

Aggregate Information. We may compile certain personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of people who have visited the Site and other user demographics. Such aggregate information does not identify you individually.

III. How We and Our Affiliates Use Personal Information

Personal information collected through the Site or Service may be used by us and our affiliates for purposes of:

Operating, maintaining, enhancing and providing you with the Service;
Responding to your questions or feedback;
Contacting you, whether by email, postal mail, or telephone with information about the Site, our products, or our services;
For such purposes as you may authorize at the time you submit the information;
Auditing, research, and analysis to maintain, protect, and improve the Site and our services;
Ensuring the technical functions of our network;
Improving and customizing the content and layout of the Site or our services;
Developing new products and services; or
Compiling personal information and other information collected through the Site on an aggregate basis.

IV. Personal Information We Share

We do not sell, rent, trade, or otherwise share personal information collected through the Site, except as described below:

In Connection with our Offerings. We may share certain personal information collected through the Site with (i) other users of the Site, and (ii) as you otherwise provide your consent.

Information which you upload, post, e-mail, submit or otherwise transmit in connection with the Site to a public message board, chat area or other public area of the Site will be made public to users of the Site, including certain metadata related to such activities (such as timestamps). You are solely responsible for any such information you choose to post on or through the Site. All information that is posted to a message board, chat area, or other public area of the Site may be shared by us with others.

Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our administrative and business purposes.

Service Providers. We work with third parties that provide services on our behalf. Such services may include website, application development, hosting, maintenance, and other services for us. We may share personal information and non-personal information with these third parties for the purpose of enabling them to provide these services. We do not bear any responsibility for any actions or policies of these third parties.

Consent. We may share personal information in accordance with any consent you provide. For example, if you are transferring your payment card account to another FI, we will require you to expressly consent to our sharing your transaction history, balances, and account information with the new FI you have selected.

Required by Law. We may disclose personal information or any information collected through the Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.

Certain Transactions. We may disclose or transfer personal information or any information collected through the Site to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

Internet-Based Advertising and Content. We may participate in Interest-based and behavioral advertising. This means that you may see advertising or content on the Site tailored to how you engage, browse or shop, or you may see advertising for us on other websites, applications and social media based on your behavior across websites, applications and social media. We may target ads or content based on data we have collected, or data provided by third parties alone or in combination with the data we collect ourselves. If you choose to interact with specific third parties who advertise through the Site, the information you provide to them is subject to the conditions of their specific privacy policies.

In connection with the foregoing activities, third parties, often called "ad servers" or "ad networks," may place and access cookies, web beacons, or other tracking technology on your device to collect information about your use of the Site and your use of third-party sites. The information about your use of the Site may be combined with information about your use of third-party websites to provide targeted advertisements and content that may be of interest to you (this is known as "behavioral advertising"). The information they collect from the Site may identify you personally, or they may associate it with personal information collected in other ways or received from other third parties. We do not control these third parties or their use of cookies, web beacons, or other tracking technology.

By using the Site you agree to usage tracking and targeted, behavioral advertising. If you do not wish to have cookies track your usage for these purposes please see the Section II.B of this Privacy Statement to refuse all or some browser cookies or do not use the Site.

Some advertisers may provide you with the choice to opt-out of having your information used for behavioral advertising. If you would like more information about behavioral advertising, or for information about how to opt-out of behavioral advertising, please visit the Network Advertising Initiative's ("NAI") consumer Web site at http://www.networkadvertising.org/understanding-online-advertising , and in particular, NAI's Ad Network "Opt-Out" page at http://www.networkadvertising.org/choices/. Even if you opt-out of behavioral advertising, we may still collect and use information about your use of the Site to the extent otherwise permitted by this Privacy Statement (such as to analyze Site traffic and usage, conduct website analytics, administer the Site, etc.). In addition, if you opt-out of receiving behavioral advertising from a particular advertiser, the advertiser may still provide advertisements to you, but the ad will not be targeted to you based on your online activities.

V. Aggregate Information

We may compile personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site, demographic information about users of the Site, and individual purchase preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.

VI. Your Choices

You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non- personal information regarding your activities on our Service and for other legal purposes as described above.

A. Email Communications

If you receive an unwanted email from us, you can use the unsubscribe link we generally include at the bottom of one of our emails to opt out of receiving future emails or you may contact us at our Email Notice Address with the "Opt-Out" as the subject line or mail us a letter to us at our Physical Notice Address. You must include your full name, email address, and postal address in your request.

Note that you will continue to receive transaction-related emails regarding products or Service you have requested. We may also send you certain non-promotional communications regarding us and our Service, and you will not be able to opt out of those communications (e.g., communications regarding the Service or updates to our Terms or this Privacy Statement).

B. Mobile Devices

In connection with your use of the Service, we may send you push notifications . You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

C. Do Not Track

Our Site does not honor "do not track" signals or other mechanisms. Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers, and you can , as described in more detail in Section II.B of this Privacy Statement, configure your browser not to accept cookies or to notify you when a cookie is being sent. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

D. California Do Not Track Disclosures

Various third-parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

E. Your Privacy Rights

In accordance with applicable law, you may have the right to request:

Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.

Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you, or a person designated by you (e.g. caregiver, family member, etc.), to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.

Deletion of your personal information, subject to certain exceptions prescribed by law.

Restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.

F. California Specific Privacy Rights

This section applies with respect to any users located in the State of California. For California residents, pursuant to the California Consumer Privacy Act of 2018, as amended ("Consumer Privacy Act"), you may (i) elect to opt out of the sale of your "personal information" (as defined by the Consumer Privacy Act) by WalletFi , (ii) request that WalletFi and its service providers delete any of your personal information collected, (iii) request that WalletFi deliver to you, free of charge, any of your personal information collected over the past 12 months preceding the request, and (iv) request certain information regarding any collection, sale, and disclosure of your personal information over the past 12 months preceding the request (including the categories of personal information collected, sold, and/or disclosed for a business purpose, the categories of sources from which the information was collected, the business or commercial purpose for collecting or selling the information, the categories of third parties with whom the information was shared, and the specific pieces of the information collected).

You may opt out of the sale of your personal information by using the following links: DO NOT SELL MY PERSONAL INFORMATION. Requests may be submitted and the foregoing rights may be exercised upon notice to us at, and questions or concerns about this Privacy Statement may be directed to, at our Email Notice Address with "California Privacy Rights" as the subject line or mail us a letter to us at our Physical Notice Address. You must include your full name, email address, and postal address in your request.

WalletFi will honor these rights to the extent required by the Consumer Privacy Act. Any requests submitted must be verified by us before we will respond, and to enable this verification we may require you to provide us information confirming your identity against the personal information we have in our records. You may submit requests through an authorized agent given authority through a power of attorney form or other authorization acceptable to and verified by us. WalletFi will not discriminate against users based on their exercise of any of the rights under the Consumer Privacy Act, provided that WalletFi may charge different prices to users based on the value of the data they provide.

The types of personal information collected in the last 12 months and how this information has been shared are as described in this Privacy Statement.

In addition, if you are a California resident, you have the right not to receive discriminatory treatment by WalletFi for the exercise of your rights conferred by the CCPA.

G. Nevada Privacy Rights - "Do Not Sell My Personal Information"

We may elect to share information about you with third-parties for those third-parties' direct marketing purposes. Nevada Revised Statutes §§ 603A.300-.360 permits Nevada residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and opt out of the sale of your personal information to third-parties for their direct marketing purposes. If this law applies to you, and you wish to make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a Nevada resident and provide a current Nevada address for our response. To make such a request, please contact us at our Email Notice Address with "Nevada Privacy Rights" as the subject line or mail us a letter at our Physical Notice Address. You must include your full name, email address, and postal address in your request.

H. General

You can exercise some of these rights by logging into your account. You can also contact us at our Email Notice Address or as otherwise set forth below to exercise any of your rights. We will process such requests in accordance with applicable laws. Please note that we may carry out deletion requests by de-identifying personal information. Additionally, we may retain information that is otherwise in de-identified and/or aggregated form, in archived or backup copies as required pursuant to records retention obligations, or as otherwise required by law. To protect your privacy, we may take steps to verify your identity before fulfilling your request.

VII. Data Retention

We store the personal information we receive as described in this Privacy Statement for as long as you use our Service or as necessary to fulfill the purpose(s) for which it was collected, provide our Service, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

VIII. Standard Contractual Clauses

To the extent WalletFi has agreements in place with any affiliates or subprocessors, each who may have access to the personal data, such agreements shall incorporate the EU Commission approved Standard Contractual Clauses ("Standard Contractual Clauses").

IX. Data Transfers

Onward Transfer. WalletFi will not disclose any personally identifiable information to a third party who is not a WalletFi contractor or agent ("Agent") except as outlined above. For third parties acting as an Agent, WalletFi will ascertain that the third party follows the Standard Contractual Clauses, is subject to the EU Data Protection Directive, or has entered into an agreement with WalletFi that is consistent with the applicable or required principles.

In the context of an onward transfer, WalletFi has responsibility for the processing of personal information it receives under the Standard Contractual Clauses and subsequently transfers to an Agent on its behalf. WalletFi shall remain liable under the Standard Contractual Clauses if its Agent processes such personal information in a manner inconsistent with such principles, unless WalletFi proves that it is not responsible for the event giving rise to the damage.

Data transfer to other controllers. Principally, your personally identifiable information is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.

Service providers (general). We involve external service providers with tasks such as sales and marketing Service, contract management, payment handling, programming, data hosting, and hotline Service. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions. Service providers may also be our affiliates.

X. Information Storage and Security

We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

XI. A Special Note about Children

The Service are not directed to children under 18 or other age as required by local law ("Approved Age"), and we do not knowingly collect or maintain information acquired through our Site from children under the Approved Age. Any user under the Approved Age should not use or access our Site at any time or in any manner. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If WalletFi learns that personally identifiable information of persons less than the Approved Age has been collected from our site without verified parental consent, then WalletFi will take the appropriate steps to delete such information and terminate the child's account.

XII. External Links and Applications

The Site may contain links to various websites or allow access to various applications (such as, but not limited to, Apple's iCloud Keychain) that we do not control. When you click on one of these links, or on one of these applications, you will no longer be transacting business through the Site. Third party websites and applications maintain their own privacy policies, and we do not exercise any control over any of the third- party websites or applications that may be linked to the Site. If you visit a website that is linked to the Site, you should consult that website's privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

XIII. Users Outside the United States

A. Transfer of Your Information

Our Service are operated in the United States and intended for users located in the United States. While we do not expect to directly market our Service to users outside the United States in any material manner, if you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, and processed, stored and used in the United States in order to provide the Service to you. Where GDPR applies and our processors of your personal information are located outside the European Economic Area, such transfer will only be to a recipient country that ensures an adequate level of data protection, or with your explicit consent.

B. Additional Rights Provided to EU Individuals

Access and Portability: You have the right to ask us to access the information we hold about you, including personal information, and be provided with certain information about how we use such information and who we share it with. Where you have provided your personal information to us with your consent, you have the right to ask us for a copy of this data in a structured, machine readable format, and to ask us to share (port) this data to another data controller.

Right to deletion: In certain circumstances, you have the right to ask us to delete personal information we hold about you:

where you believe that it is no longer necessary for us to hold your data including personal information;
where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; or
where you believe the personal information we hold about you is being unlawfully processed by us.
Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:
where you believe the personal information we hold about you is inaccurate and while we verify accuracy;
where we want to erase your personal information as the processing is unlawful, but you want us to continue to store it;
where we no longer need your personal information for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defense of legal claims; or
where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your Personal Information based on our legitimate interests and we will no longer process your Personal Information unless we can demonstrate an overriding legitimate ground.

To exercise any of these rights above, please contact us at our Email Notice Address.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals, where there are overriding public interest reasons, or where we are required by law to retain your personal information.

You can withdraw your consent at any time by contacting us at our Email Notice Address.

Complaints: In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at our Email Notice Address and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority.

XIV. Governing Law and Jurisdiction

Any questions or concerns regarding the use or disclosure of personal information should be directed to WalletFi pursuant to the Physical Notice Address. WalletFi will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Statement.

Any claims relating thereto will be governed by the laws of the State of North Carolina, excluding the application of its conflicts of law rules. You agree that any controversy or claim arising out of or relating to this Privacy Statement, or the breach thereof, shall exclusively be brought in a state or federal court located in Wake County, North Carolina.

XV. Updates to this Privacy Statement

We may revise this Privacy Statement from time to time in our sole discretion. If there are any material changes to this Privacy Statement, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Statement if you, or a person designated by you (e.g. caregiver, family member, etc.), continue to use the Service after the new Privacy Statement takes effect.

XVI. Questions Regarding this Privacy Statement

If you have any questions or comments regarding our privacy practices or this Privacy Statement, or if you wish to submit a request to exercise your rights as detailed in this Privacy Statement, please contact us at our Email Notice Address or our Physical Notice Address.

This Privacy Statement is effective as of July 30, 2021

Last Updated: July 30, 2021