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Effective Date: 05/01/2025

Last Updated: 05/05/2025

This Privacy Policy explains how CIVYL Financial Inc. DBA CIVYL (“we,” “our,” or “us”) collects, uses, and protects your information when you use our website, mobile application, or services (collectively, the “Services”).

By using our Services, you agree to the collection and use of information in accordance with this policy.

Information We Collect

We may collect the following types of information:

• Personal Information: Name, address, phone number, email address, date of birth, Social Security number, and government-issued ID (for identity verification).
• Financial Information: Bank account numbers, direct deposit information, transaction history.
• Device Information: IP address, device ID, browser type, location, and operating system.
• Usage Data: Information about how you interact with our app or website.

How we Use Your Information

We use your information to:

• Provide and manage your account
• Process mobile check deposits and direct deposits
• Enable peer-to-peer payments (if offered)
• Deliver early wage access or pay advances
• Comply with legal and regulatory obligations (KYC/AML)
• Prevent fraud and unauthorized activity
• Communicate with you (service notices, promotions, updates)

3. Sharing Your Information

We may share your data with:

• Banking-as-a-Service partners and sponsor banks
• Identity verification and check processing providers
• Service providers (e.g. cloud storage, analytics)
• Government agencies and law enforcement (when legally required)

We do not sell your personal information to third parties.

4. Data Security

We use industry-standard security measures, including encryption, secure servers, and access controls to protect your information. While we strive to protect your data, no method is 100% secure.

5. Cookies and Tracking

We may use cookies and similar technologies to enhance your user experience and monitor app performance.

6. Your Rights and Choices

You may request to:

• Access or correct your personal information
• Delete your account or personal data (subject to legal obligations)
• Opt out of promotional emails

Email us at support@bankwithcivyl.com for requests.

7. Children's Privacy

Our services are not intended for children under the age of 13. Youth accounts must be opened by a verified parent or guardian.

8. Updates to This Policy

We may update this Privacy Policy periodically. We’ll notify you of material changes via email or app notice.

9. Contact Us

If you have questions, contact us at:

Email: support@bankwithCivyl.com

Address: PO Box 130097

Springfield Gardens NY 11412