Privacy Policy

General Purpose

Moxie Money, LSP. ("Moxie" or "we" or "our" or "us"), has developed this Privacy Notice to explain our collection, use and disclosure of personal information during our interactions with you online via our websites (collectively, the "Site") and applications that link to this Privacy Notice (our "Sites") or via our Services (as defined below).

This Privacy Notice is intended to summarize and inform our customers and users ("users" or "you") of our online privacy and data protection practices regarding the collection, use, and disclosure of personal information when you use our Services, to inform our customers and other users about how we define, gather and utilize personal information, and how personal information is used, shared, and secured, and how you can take steps to exercise and protect your privacy rights.

This Privacy Notice applies to personal information processed by us in our business, including on our Site and other online or offline means, such as via email, at in-person events or service calls, via phone, or from third-party sources where you have consented to the sharing (collectively, the "Services"). For information on how to contact us, please refer to the Questions and Feedback section below.

Job candidates and employees: Please see our Applicant and Employee Privacy Notice available on our career site.

Acceptance of this Privacy Notice; Updates to this Privacy Notice

By accessing the Site or using our Services, you acknowledge that you have read and understand the Privacy Notice and that we will collect, use and share your information as set forth below. Moxie reserves the right, at its sole discretion, to change, modify, add, or remove portions of this Privacy Notice at any time for any reason. Each time you use the Services, the current version of the Privacy Notice will apply. Accordingly, your continued use of the Services following a change in the Privacy Notice represents your acceptance of the new Privacy Notice to the fullest extent permitted by law. We suggest that you regularly review this Privacy Notice and our Terms of Use for changes and to ensure that you understand and accept our privacy practices and your obligations in accessing and using the Services.

Definitions

For the purposes of this Privacy Notice:

"Personal information" generally means any information which relates to an identifiable person. It may include names, identification numbers, addresses, telephone numbers, email addresses, and other information that, alone or in combination with other information, may be used to identify a person. Personal information does not include: deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you or a particular household or publicly available information from government records.

"Processing" covers all activities relating to the use of personal information by Moxie, from its collection through to its storage and disposal and every phase in between.

Collection

We gather information on our Site from users by tracking pages visited and collecting information from voluntary submissions. We may use various technologies as well (e.g., cookies) to collect information from your computer and about your activities on our Site. We collect aggregate information regarding which pages of our Site users access or visit. We gather your information on our Services depending on the type of interaction you have with us and may include information gathered automatically via your interaction with features such as email or collected from voluntary submissions such as in response to telephone prompts or provided to us by third parties such as information on event registrants.

Categories of Data We Collect

We may collect the following categories of personal information about you (the categories and examples of data collected will depend on how you interact with our Services):

• Personal Identifiers, such as name, alias, signature, telephone number, postal address, email address, unique personal identifier, online identifier, internet protocol address, account name, social security number or other government issued identification number, driver’s license number, passport number, financial account number or information.

• Internet and Technical Information, such as internet protocol address, data from cookies, data from web beacons, device identifiers, server log records, browsing history, search history, interaction with a website, application or advertisement, interaction with marketing emails, geolocation, etc.

• Geolocation Information, such as location information from your device or estimated based on your IP address.

• Corporate Affiliation, such as employer, relationship to our company and business title.

• Communications, such as content of communications you send to us.

• Social Media Content, such as community discussions and comments on our Sites and any other information that is publicly available or that you consent to making available on corporate social sharing sites.

• Audio, Video, or Visual Information, such as call recordings, teleconference or videoconference recordings of interviews, meetings, trainings and other events, photographs, voicemails, closed-circuit monitoring (CCTV), etc.

• Survey Information, such as information and responses you provide when responding to survey information.

• Individual Profiles, such as inferences drawn from other personal information, including preferences, characteristics, behavior, etc.

• Miscellaneous Information, any other voluntarily provided information in connection with our Sites, such as information you enter into a free text form.

We may also collect commercial information related to any entity seeking to obtain financial services through us.

Automatic Data Collection and Tracking

Usage Data

We also collect certain passive tracking data concerning how the Site is accessed and used ("Usage Data"). This Usage Data includes information such as your computer’s Internet Protocol ("IP") address, browser type, browser version, the pages of our websites that you visit, the times and dates of your visits, the time spent on those pages, and diagnostic data.

Tracking Data and Cookie Policy

We use cookies and other online tracking technologies to understand visitor activity on our Site, and to hold certain information about your visits to help improve your experience while using the Site.

A cookie is a text file sent by a web server and placed on your computer by your web browser. Cookies can be divided into two different types: "session" and "persistent." Session cookies differ from persistent cookies primarily in that session cookies are temporary and expire and are normally deleted when you close your browser. Persistent cookies, in contrast, remain stored on your computer after you close your browser until they are deleted either because they expire, or you delete them. Moxie uses session cookies and persistent cookies in connection with providing our Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Cookies are often used in conjunction with other Internet technologies, such as web beacons, to understand behavior on the Internet. "Local shared objects," "LSOs," or "flash cookies" are data files similar to cookies, except that they can store more complex data. "Web beacons," "clear pixels," "clear GIFs," or "pixel tags" are small graphic images on a webpage or in an email. A "web server log" is a record of activity created by the computer that delivers the webpages you request to your browser. A "widget" is a program or application that can be embedded in a web page or mobile application.

The types of cookies and other tracking technologies we use are: Session Cookies (to operate our Site and for security purposes); Persistent Cookies (to remember your preferences and various settings); Local Shared Objects (to remember your settings, preferences, and usage); Web Beacons (e.g., recording the pages and advertisements clicked on by users or tracking the performance of email marketing campaigns); Web Server Logs (e.g., recording information about your browser, the search term you entered or link you clicked); and Widgets (to allow third parties to collect data about users viewing the Site or interacting with that widget, possibly subject to privacy policies other than this one).

In general, our purposes for using the above technologies are: Analytical (to analyze user activity in order to improve the Site); Your Preferences and User Experience (to store user preferences and make your experience more consistent and convenient); Referral Tracking (to associate user activity with the third-party website or email campaign that referred you); Security (to limit certain types of cyber-attacks and other data security incidents); Testing, Usability, and Performance (to conduct A/B testing and improve performance and reliability); and Fraud/Spam Prevention (during fraud reviews and investigations).

Analytics

We may use third-party Website Providers to monitor and analyze the use of our Site.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google Analytics is deployed only on Moxie’s public marketing pages. Google Analytics is not active on authenticated borrower pages, loan application forms, document upload pages, or account servicing pages where personal financial information may be entered or displayed. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having your activity on the Site made available to Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout). For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/.

Marketing

We use marketing services to advertise on third-party websites to you based on your activity on our Services only (and not activities outside our Services), after you have visited our Site. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Site. You can adjust your settings to opt out of marketing cookies and related tracking technologies.

Opting-Out

You may reset your browser to refuse all cookies or to allow your browser to alert you when a cookie is set, however, certain parts of the Site may not be available or may function differently and not as well. Unless you have adjusted your browser setting so that it will refuse cookies, our Site will issue cookies when you log on to the Site. For more information about how to manage your cookie preferences, you should use the "help" menu of your web browser or explore the customer support sections of your web browser. Please note that you need to configure each browser on each device that you use if you wish to opt-out or block some or all cookies.

"Do Not Track" Signals

Moxie uses online tracking tools to complete Site analytics and provide customized advertising (as described above) but does not track its customers over time and across third party websites to provide targeted advertising. However, where available, you may enable a browser tool that automatically communicates your universal opt out or Do Not Track ("DNT") signal. When detected, we will process such a signal as an opt-out of tracking request. Some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal or universal opt-out mechanism so that third parties (particularly advertisers) know you do not want to be tracked.

Sources of Personal Information We Collect

We (ourselves or via our service providers) collect personal information directly from you, from third-party sources, or from publicly available sources, such as search engines, career networking sites, public databases, etc. We also collect personal information through automated means, such as cookies and web beacons.

In addition, Moxie employs software programs to identify unauthorized access or access to nonpublic information, detect computer viruses and other software that might damage Moxie’s computers or the network, and monitor and fine-tune the performance of our network. These programs may detect additional information from your computer such as your IP address and other technical information. This information is used only for the purpose of maintaining the security and performance of our Sites, networks and computer systems.

Use of Personal Information

We process your personal information in accordance with applicable laws. We may use any personal information collected pursuant to this Privacy Notice:

• To provide our Services, products, and features to you;

• To manage the Site;

• To measure and improve those Services, products, and features;

• To develop internal and external analyses;

• To contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;

• To contact you with newsletters, marketing or promotional materials and other information that may be of interest to you (you may opt out by following the unsubscribe link or instructions provided in any email we send or by contacting us);

• To facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements;

• To administer, operate, facilitate, and manage your relationship and/or account with us, which may include sharing such information internally, as well as disclosing it to our affiliates or other third parties, such as the Small Business Administration;

• To protect our users and provide them with customer support;

• To audit downloads of information from the Site and make follow-up contact with you by email in relation to the material you have accessed; and

• Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

We may also disclose or process de-identified information for legitimate and lawful business purposes. Where we have de-identified data, we will maintain and use it without attempting to re-identify the data other than as permitted under law. We do not use sensitive personal information to infer characteristics about our business contacts or outside of the permitted purposes set forth under Section 7027(m) of the CCPA regulations.

Disclosure and Transfer of Personal Information

Except as set forth in this Policy, Moxie will not disclose, share or sell your personal information. Personal information may occasionally be transferred to Moxie affiliates and to third parties who act for or on behalf of Moxie or in connection with the business of Moxie, for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services we provide. Such third parties may operate under different privacy policies.

We may disclose your information with the following categories of third parties: Third-Party Providers; Vendors and Service Providers; Advisors (including lawyers, financial advisors, accountants, consultants, and insurers); Experts (including technical consultants and forensic analysts); Affiliates and Subsidiaries; Public and Government Entities; Regulators and Law Enforcement; and in connection with a Merger, Sale, or Other Asset Transfer.

We disclose the following categories of personal information to the following categories of third parties where necessary, appropriate, or required for a business purpose:

Sale of Personal Information

We allow certain third parties to use cookies and other online tracking technologies to collect personal information on our Sites to support our business purposes. These third parties may analyze activity and help us personalize your experience. These third parties may also provide free or enhanced add-on services to our company, and they may use your personal information for purposes beyond the services they provide to our company. These types of online exchanges of personal information may be defined as "sales" or "sharing" under applicable law(s), with some exceptions. We may "sell" or "share" (as defined by the law) the following categories of personal information to third party online analytics and advertising providers: personal identifiers; internet and technical information; corporate affiliation information (to the extent it can be derived from your activity on our Sites).

Retention of Personal Information

Moxie endeavors to assure that all personal information is processed by entities with reasonable safeguards in place that are in accordance with the nature and sensitivity of such personal information. We will retain your personal information as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the personal information. If your relationship with Moxie ends, we will continue to treat your personal information, to the extent we retain it, as described in this Privacy Notice.

Your Choices

Please note that these choices apply only to the information we process and the communications we send, and not to any information processed or communications sent by our Bank Partner. To exercise any choices you may have regarding your relationship with our Bank Partner under its Privacy Notice, please contact the Bank Partner directly.

General

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 Site and for other legal purposes as described above.

Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

You hereby expressly consent that Moxie and its agents, assignees, successors, and servicers may call or send text messages (including SMS and MMS) to you at any phone number you provide in relation to your application, Agreement, or account, using any automated dialing equipment or system, or an artificial or prerecorded voice, even if your phone number is registered on any state or federal Do Not Call list. You understand and agree that calls and/or texts may include telemarketing. You agree to provide Moxie any additional or replacement phone numbers you may obtain, and to promptly notify Moxie if a previously provided telephone number is no longer your number. Your mobile carrier may charge its standard text message rates. Calls to or from Moxie may be monitored and recorded, and you expressly consent to such monitoring and recording.

Mobile Devices

We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, 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.

Children’s Privacy

Our Site is intended for adults over the age of 18, and we do not knowingly collect information about children or sell products or services to children. We do not knowingly collect personal information from anyone under the age of 18. If you are under 18 please do not continue using the Site. If we become aware that we have collected personal information from children we will take steps to remove that information from our servers.

Your Rights With Respect to Your Personal Information

Only you, or someone legally authorized to act on your behalf (an "authorized agent"), may make a verifiable request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may have the following rights regarding your personal information under applicable laws, subject to a number of exceptions and limitations. Please note that these rights apply solely to information that we process, and not to information processed by our Bank Partner.

Right to Access Information

You may have the right to request access to the specific personal information we have collected about you, or to request the categories of personal information we have collected; the categories of sources; the business or commercial purposes for collecting, selling, or sharing; the categories of third parties with whom we share; the categories of personal information sold and to whom; and the categories disclosed for a business purpose and to whom.

Right of Rectification or Correction

You may have the right to have your personal information rectified or corrected if that personal information is inaccurate or incomplete. Account holders are able to edit and update most of their personal information held by Moxie on the Site, and if you have any queries or complaints, we encourage you to contact us at privacy@moxiesmb.com. Alternatively, you may make a formal request to have Moxie rectify any inaccurate personal information on your behalf via any of the methods listed below under "Exercise Your Rights."

Right of Data Portability

You may have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format (or have this transferred to a third party) to the extent technically feasible. If you have any queries or complaints, we encourage you to contact us at privacy@moxiesmb.com.

Right of Deletion, Anonymization, or Blocking

You may have the right to request that we delete, anonymize, or block your personal information under certain conditions, such as when processing is based on your consent or when processing is unnecessary, excessive, or noncompliant. If you have any queries or complaints, we encourage you to contact us at privacy@moxiesmb.com. Once your request has been confirmed, Moxie will initiate the necessary steps to execute this procedure to the extent required by applicable law.

Right to Opt-Out of Sale or Sharing

You may have the right to opt-out of the sale or sharing of your personal information, as defined under applicable law. To exercise your right to opt-out of sales or sharing, please email us at privacy@moxiesmb.com. To opt-out of cookie-based sales or sharing of information you may manage your cookie preferences using the "help" menu of each browser on each device.

Right to Withdraw Your Consent

You may have the right to withdraw your consent to our processing of your personal information where we rely on consent as the basis for processing. If you refrain from providing personal information or withdraw your consent to processing, some features of our services may not be available. If you have any queries or complaints, we encourage you to contact us at privacy@moxiesmb.com.

Right of Non-Discrimination

You have the right not to receive discriminatory treatment by us when you exercise your rights.

Right to Appeal

In certain cases, you have the right to appeal if we deny your privacy request. If your request is denied, we will provide additional instructions on the appeals process. Please contact privacy@moxiesmb.com if you wish to appeal. We will consider your request and applicable law and notify you of our decision.

Right to File a Complaint

You have the right to report concerns about our privacy practices, including the way we’ve handled your personal information, to the relevant supervisory or regulatory authority. If you would like to receive contact information for your local authority, you may contact us as provided below.

Some Limitations

The above data rights are subject to certain limitations, as provided for by applicable laws, including the GLBA and state privacy laws. Individual requests will be completed within the time allotted by relevant regulations. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by Moxie and only imposed to the extent permitted by applicable law.

Verification. To protect your privacy, where permitted or required by law, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Authorized Agents. In certain circumstances, you are permitted to use an authorized agent to submit a privacy request on your behalf. We may verify the authorized agent’s authority to act on your behalf, which may include requiring signed permission and direct verification of your identity with us.

Exercise Your Rights

To exercise the rights listed above, send an email to privacy@moxiesmb.com. We will process such requests in accordance with applicable laws.

Links to Other Sites

This Privacy Notice applies only to Moxie Sites and not to third-party websites. Moxie may include links to other websites that we believe may be of interest to our visitors. We aim to ensure that such websites meet the highest standard. However, due to the nature of the World Wide Web, Moxie cannot guarantee the standards of every website link it provides or be held responsible for the contents of non-Moxie sites. We encourage you to be aware when you are leaving Moxie Sites and read the Privacy Notice of the site that you visit prior to providing any personal information.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to safeguard personal information, including physical, technical, and administrative measures to protect the information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use generally acceptable means to protect your information, we cannot guarantee its absolute security. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Site, by mail or by sending an email to you.

Supplemental Notices

California Shine the Light

If you are a California resident, under California Civil Code sections 1798.83-1798.84, California customers are entitled to annually request and obtain information free of charge about what categories of personal information we shared with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please email us at privacy@moxiesmb.com from the email address associated with your account to ensure a timely response to your request.

Questions and Feedback

If you have any questions, comments, or concerns about our privacy practices or this Privacy Notice, or you wish to submit a request to exercise your rights as detailed in this Privacy Notice, please send an email to privacy@moxiesmb.com.